WHX Flare and Blowdown

Independent Verification of WHX
New Flare and Blowdown System

Pharaonic Petroleum Company
5119652/PR-REP-001/Rev 0
July 2013
Independent Verification of WHX New Flare and Blowdown System -
Independent Verification of WHX New Flare and Blowdown System
A Report Prepared by
Atkins
On Behalf of
COMMERCIAL IN CONFIDENCE
Atkins Pharaonic Petroleum Company

200 Broomielaw 70/72 Rd 200
Glasgow Digla
G1 4RU Maadi
Cairo
Tel: 0141 220 2000 Tel: 00 202 27725900

Fax: 0141 220 2001 Fax: 00 202 2517049
Report No: 5119652/001/PR-REP-001/Rev 0 Page 2

Issue Date: July 2013
DOCUMENT ISSUE CONTROL SHEET
Independent Verification of WHX New Flare and Blowdown System
Document History
Issue Date Purpose Rev Prepared Checked Approved
1 June 2013 Draft for Client Comment 0 GRD/AJR AJR/GRD GRD
Notice
This report was produced by WS Atkins International Limited for Pharaonic Petroleum Company for
the specific purpose of Independent Verification of WHX New Flare and Blowdown System.
This report may not be used by any person other than Pharaonic Petroleum Company without
Pharaonic Petroleum Company’s express permission. In any event, Atkins accepts no liability for any
costs, liabilities or losses arising as a result of the use of or reliance upon the contents of this report
by any person other than Pharaonic Petroleum Company.

Contents
Section Page
Summary ................................................................................................................................................ 7
1. Introduction .............................................................................................................................. 8
2. Glossary of Terms .................................................................................................................... 9
3. Recommendations .................................................................................................................10
4. Compliance with ETPs and International Standards ..........................................................18
4.1 Applicable Engineering Standards ...........................................................................................18
4.2 Areas of Non-Conformance .....................................................................................................18
5. Relief Load Verification .........................................................................................................21
5.1 100% Area Checks ..................................................................................................................21
5.1.1 Vapour PSVs ............................................................................................................................21
5.1.2 Liquid PSVs ..............................................................................................................................22
5.1.3 Blowdown Valves .....................................................................................................................22
5.2 Critical Device Verification .......................................................................................................23
5.2.1 Findings – General ...................................................................................................................23
5.2.2 Findings – Undersized Devices ...............................................................................................24
5.2.3 Findings – Oversized Relief Devices .......................................................................................31
6. Verification of Disposal Systems .........................................................................................33
6.1 Disposal System Design ..........................................................................................................33
6.1.1 Flare Loads ..............................................................................................................................33
6.2 Relief Device Selection ............................................................................................................34
6.2.1 Backpressure limitations ..........................................................................................................34
6.2.2 Service .....................................................................................................................................35
6.2.3 Speed of Response ..................................................................................................................36
6.2.4 Multiple Relief Valves ...............................................................................................................36
6.2.5 Design Temperature .................................................................................................................. 1
6.3 Relief Device Inlet Piping ........................................................................................................... 1
6.3.1 Drainage and Blockages ............................................................................................................ 1
6.3.2 Inlet Pressure Drop .................................................................................................................... 1
6.3.3 Winterisation .............................................................................................................................. 2
6.4 Relief Device Tailpipes and Flare Headers................................................................................ 2
6.4.1 Flare Model ................................................................................................................................ 2
6.5 Liquids Handling ......................................................................................................................... 2
6.5.1 Piping ......................................................................................................................................... 2
6.5.2 Flare Knock Out Drums.............................................................................................................. 3
6.6 Design and Construction ............................................................................................................ 4
6.6.1 Relief Segregation ...................................................................................................................... 4
6.6.2 Low Temperature Relief ............................................................................................................. 4
6.6.3 Facilities for Drainage ................................................................................................................ 4
6.6.4 Facilities for Isolation .................................................................................................................. 5
6.6.5 Structural Supports .................................................................................................................... 5
7. Emergency Shutdown and Depressurisation ....................................................................... 6

7.1 Emergency Shutdown ................................................................................................................ 6

7.2 Instrument Protections ............................................................................................................... 6
7.3 Emergency Depressurisation ..................................................................................................... 8
7.3.1 Philosophy .................................................................................................................................. 8
7.3.2 Methodology ............................................................................................................................... 8
7.3.3 Review of Depressurisation ....................................................................................................... 8
8. Flare Stacks and Atmospheric Vent Stack ..........................................................................10
8.1 Atmospheric Vents ...................................................................................................................10
8.2 Flare Stacks .............................................................................................................................10
8.3 Flare Purges and Flashback Prevention ..................................................................................11
9. Other Areas of Concern.........................................................................................................12
9.1 Acoustic Induced Vibration ......................................................................................................12
9.2 Relief and Overpressure System Dossier ................................................................................13
10. References ..............................................................................................................................16
List of Tables
Table 2.1 – Glossary of Terms 9
Table 4.1 – Non-conformances with ETPs 20
Table 5.1 – Over-sized vapour safety valves 22
Table 5.2 –Liquid relief valves 22
Table 5.3 – Relief Loads for Glycol/HC Separator 24
Table 5.4 – Relief Loads for Condensate Preheater Tubeside 24
Table 5.5 – Relief Loads for Condensate Preheater Shellside 25
Table 5.6 – Relief Loads for Condensate Stabiliser 25
Table 5.7 – Relief Loads for Ha’py Slugcatcher 26
Table 5.8 – Relief Loads for Gas/Gas Exchanger Shellside 26
Table 5.9 – Relief Loads for HP Fuel Gas KO Drum 27
Table 5.10 – Relief Loads for LP Fuel Gas KO Drum 27
Table 5.11 – Relief Loads for Nitrogen Distribution Header 28
Table 5.12 – Relief Loads for Water/HC Separator 29
Table 5.13 – Relief Loads for Condensate Train 30
Table 5.14 – Relief Loads for Taurt Slugcatcher 30
Table 5.15 – Relief Loads for Methanol Storage Tank 31
Table 5.16 – Relief Loads for Compressor Suction Drum 31
Table 5.17 – Relief Loads for Compressor Discharge Drum 32
Table 6.1 – Balanced bellows valves exceeding backpressure allowance 35
Table 6.2 - Critical PSV’s with Inlet line pressure drop outside acceptable limits 1
Table 6.3 - Flare model constraints 2
Table 9.1 - Summary of Current Flare Documentation against GP44-70 15
List of Figures
No table of figures entries found.

Appendices
Appendix A 100% Area Checks ....................................................................................................... A-1
A.1 Vapour PSV Area Check........................................................................................................ A-2
A.2 Liquid PSV Area Check.......................................................................................................... A-7
A.3 Blowdown Orifice Area Check ............................................................................................... A-8
Appendix B Critical Relief Device Evaluation ................................................................................ B-1
B.1 Critical Relief Device Summary ............................................................................................. B-2
Appendix C Relief Device Selection ................................................................................................ C-1
C.1 Relief Device Selection .......................................................................................................... C-2
Appendix D Inlet Line Verification ................................................................................................... D-1
D.1 Inlet piping drainage, isolation and winterisation ............................................................ D-2
D.2 Inlet Line Losses Calculations ............................................................................................. D-14
Appendix E Tail Pipe and Flare Header Summary ......................................................................... E-1
E.1 Tail Pipe Summary ................................................................................................................. E-2
E.2 Sub-header Summary ............................................................................................................ E-6
E.3 Header Summary ................................................................................................................... E-8
Appendix F HP Wet Flare model Review ........................................................................................ F-1
F.1 Review of HP Wet Flare Model .............................................................................................. F-2
Appendix G Calculations ..................................................................................................................G-1
G.1 Calculations ............................................................................................................................G-2
List of Tables
Table A.1 – Check on Area and Selected Orifice for Relief Devices in Vapour Service A-6
Table A.2 – Check on Area and Selected Orifice for Relief Devices in Liquid Service A-7
Table A.3 – Check on Blowdown Orifice Area A-9
Table B.1 – Comparison of Critical Devices B-8
Table C.1 – Relief Device Selection C-6
List of Figures
No table of figures entries found.

Summary
An independent verification exercise has been carried out on the West Harbor Expansion Project’s
new flare and blowdown systems by Atkins, at the Execute project stage, on behalf of the Pharaonic
Petroleum Company. The review covers the new facilities.
The review has been carried out in accordance with, and fulfilled the scope of; the Terms of
1
Reference and any exceptions are highlighted in the documentation. It should be noted that the
review is not yet complete and this is an interim report only. The report structure is based on the
headings used in the ToR.
Areas of non-conformance with current BP ETPs are noted in Section 4.2 for Project’s consideration.
In addition, where appropriate, a number of recommendations have been made throughout the report
and summarised in Section 3. There are a number of findings which will need further thought as to
how they should be addressed depending upon impact and given the current Project status.
Key findings are as follows:
 Across all areas reviewed there was inadequate documentation detailing key decisions and
justification for the current design of the overpressure protection and disposal systems. Given
the advanced status of the design this should be addressed urgently and, if necessary, subject to
further review against the requirements given in the BP ETPs;
 Of the 21 critical devices reviewed 5 were calculated by Atkins to be the same size, 13 were
undersized, 2 were oversized and for 1 device the current size is unknown and could not be
confirmed;
 There is a concern that LOPA may have taken inappropriate credit for layers of protection in
arriving at IL ratings and there is a lack of transparency around why the LOPA (final) reported IL
ratings have been reduced in the SIL Verification Study. This is an area which should be given
further close attention.

1. Introduction
The industry has experienced an increase in incidents due to inappropriately designed or operated
relief and blowdown systems in the past few years. These systems are of critical importance in
maintaining safe and reliable operations and represent the last line of defence for a facility with
respect to personnel and public safety.
In order to identify and eliminate deficiencies in the design of the relief and blowdown systems and to
provide assurance on the adequacy of the proposed systems the Pharaonic Petroleum Company
(PhPC) have instructed Atkins to carry out an independent verification of the new flare and blowdown
system added as part of the West Harbor Expansion Project.
It should be noted that verification has been carried out only for:
 the new facilities
 the impact of the new facilities on overall issues of flare system capacity, radiation and dispersion
Verification of existing facilities has in general not been carried out.
This report summarises the verification exercise carried out on the blowdown, flare, relief and vent
systems between April and May 2013.

2. Glossary of Terms
Abbreviation Definition
AIV Acoustically Induced Vibration

API American Petroleum Institute
ASME American Society of Mechanical Engineers
BOD Basis of Design
BUBP Built-up Back Pressure
CFD Computational Fluid Dynamics
CV Control Valve
EA Engineering Authority
ESD Emergency Shutdown
FEED Front End Engineering Design
HAZOP Hazard and Operability Study
HC Hydrocarbon
HP High Pressure
IL Integrity Level
IPS Instrumented Protection System
KO Knock-out
LOF Likelihood of Failure
LOPA Layer of Protection Analysis
LP Low Pressure
LT Low Temperature
LTCS Low Temperature Carbon Steel
PAHH Pressure Alarm High High
PSD Process Shutdown
PSHH Pressure Switch High High
PSV Pressure Safety Valve
PWL Sound Power Level
RO Restriction Orifice
SIL Safety Integrity Level
SIS Safety Instrumented System
USD Unit Shutdown

Table 2.1 – Glossary of Terms

3. Recommendations
The following summarises the recommendations that have arisen throughout the report:
Recommendation 1 – Section 5.1.3
RO vendor should confirm that the Project’s required rates can be achieved through supplied orifice.
Recommendation 2 – Section 5.2.2.1
The potential paths for reverse flow through the Condensate Recirculation Pump, 0210-PB-001,
should be reviewed and 0210-PSV-021A/B sized accordingly.
The wetted area of the Glycol/HC Separator, 0210-VA-001, should be reviewed and the fire load
updated.
The orifice size of 0210-PSV-1005 should be increased from a D to an E.
The orifice size of 0210-PSV-1006 should be increased from an E to a G.
Project should review the build-up of condensate within the Ha’py slugcatcher and revisit fire relief
calculations.
Project should consider installing a restriction orifice in 0320-FCV-103 bypass line to restrict the flow
to no greater than that which can be passed by the control valve and can be handled by the installed
relief valves. Additionally, bypass should be locked closed to ensure it cannot be opened when the
control valve is in use.
The Cvs for 0420-PV-201 and 0420-PCV-202 should be confirmed, calculations revised and the valve
orifice size increased from a K to an L as necessary.
Calculations across letdown stations should be carried out based on the maximum operating pressure
for the high pressure system, this is typically the high pressure trip setting or PSV set pressure where
no trip exists.
Project should justify the use of a Cv of 3.192 for the manual bypass valve around 0420-PV-007A/B
or resort to a more typical valvue for a 1” manual globe valve.
Project should source the installed Cv of 0420-PV-007A/B and 0420-PV-1104 and update calculations
for 0420-PSV-1008A/B as required. These Cvs are safety critical items and should be documented
as such.
0600-PSV-1006A/B on the Nitrogen Distribution Header should be replaced with a G orifice valve.


Project should consider lowering the set pressure of 0850-PSHH-006 from 110 barg such that it
provides an additional layer of protection before the Slugcatcher PSVs which also have a set pressure
of 110 barg. In addition it will reduce the relief load on 0850-PSV-002A/B on the Water/HC Separator,
0850-VA-001.
Where control valve failure results in an ovepressure scenario it is imperative that vendor Cvs are
used in the relief device sizing calculations to ensure that the device is adequately sized. Project
should obtain Cvs for all such valves and ensure that they are reflected in the relief calculations.
These valves and associated Cvs should be documented in the Relief and Overpressure System
Dossier.
0850-PSV-1005 should be resized for liquid displacement in the event of gas blowby. In accordance
with GP 44-70 ISD principles should be applied in selecting design pressure and corresponding set
pressures for the downstream system and relief device.
Inadvertent opening of 0850-SDV-001 without depressuring and the sealine at maximum pressure of
144 barg will result in an extremely large load. Given that this load will exceed the capacity of the
flare system, an IPS will be required. Project should review existing overpressure protection and
confirm that it is sufficiently robust and reacts quickly enough to protect the downstream systems.
Project should source all relevant data and review sizing of 0850-PSV-1025.
Project should confirm that the flare design has considered all coincident flaring cases.
Project should produce a comprehensive Relief, Flare and Blowdown Report which clearly identifies
and justifies the design basis for each of the flare systems. This report should also contain the output
of any supplementary studies, e.g. low temperature, ice/hydrates, or as a minimum reference these.
If the LP Flare system capacity has been rerated it should be clearly stated as such. It should also be
confirmed that the flare system in its entirety is good for the higher rate and not just the flare tip.
Confirm that loads based on FEED design are still valid.
Recommendation 22 – Section 6.2
The maximum and minimum project design pressure and temperatures should be reviewed against
valve design pressure and temperature, and valves confirmed acceptable.
Datasheets for existing valves have not been provided. Project should confirm that the existing
valves have been reviewed and are suitable for new conditions.
Back pressures for conventional relief valves should be updated on PSV datasheets.


The built up back pressures for all balanced relief valves should be calculated and the datasheets
updated.
The back pressures acting on 0210-PSV-012A/B, 0210-PSV-032, 0210-PSV-1006, 0210-PSV-1007
and 0320-PSV-1027A/B should be reviewed.
The back pressures for all PSVs should be confirmed and PSV datasheets, calculations and sizing
verification report updated accordingly.
Appropriate backpressure correction factors should be incorporated into the sizing calculations for
balanced bellows and pilot operated valves where required.
Confirm with manufacturer that the backpressures expected are acceptable for adequate operation of
the specified relief valves.
The worst case back pressures for all pilot operated relief valves should be confirmed and the
datasheets and calculations updated.
PSVs 0320-PSV-1030A/C should be specified as safety relief valves and that ethylene glycol is will be
present under some relieving conditions.
Project should review and confirm that all relief devices have been appropriately selected to function
adequately across all potential relief scenarios. Where safety valves are expected to be used to
relieve liquid under certain scenarios, the valve capacity should be reviewed and confirmed as
acceptable with derating factor applied.
Update calculations so they are consistent with data listed on the datasheets.
Project should confirm that all critical device inlet lines meet the minimum slope of 1:400.
The piping configuration for the inlet lines to 0210-PSV-1028A/B, 0210-PSV-1005, 0420-PSV-
1008A/B, 0600-PSV-1006A/B and 0850-PSV-1025 to ensure the pressure drop as a percentage of
set pressure is below the required project limits.
Confirm if the pilot operated valves require remote sensors and update datasheets accordingly.
Project should confirm that the potential for blockage of the PSV inlet lines and impulse lines due to
hydrate formation has been considered and appropriate measures are in place.


The flare model should be updated to provide an accurate model of the network in order to size
headers and sub headers correctly and evaluate the back pressures within the system.
All error messages in the flarenet model which have been flagged up should be resolved.
It should be confirmed that the piping systems associated with those relief valves which may see
multi-phase relief are noted as such on the line list and subjected to screening and, if required, full
stress analysis.
Reference should be made in the Wet HP and LP Flare KO Drums verification reports, and
associated calculations, to the documents from which the source data was drawn – flowrates,
densities and viscosities. The flowrates and the derivation of these for the varying sizing cases should
also be detailed in the Flare and Blowdown BOD document, and the Existing & New De-pressuring
Systems Verification Report ENP-WHUPZZ-PR-REP-1050, G1.
If, following response to the recommendations in section 6.1.1.1, the design flowrates are amended,
the KO Drum sizing will have to be re-evaluated.
There is an overfill case for the LP flare KO Drum from the water/HC and glycol/HC separators, as
included in the LOPA report. Project should confirm that this has been considered in confirming that
the liquid surge volume in the LP Drum conforms with the requirements of GP 44-80.
CFD analysis is required for confirmation of liquid separation efficiency of the flare KO drums and for
assessment of the impact of the inlet diverter on separation, in line with 10.2.c of GP 44-80.
Project to confirm if there is an intention for incoming / outgoing gas pipeline to be de-pressured
through the flare system and if this is intended, quantify maximum de-pressuring rates, liquid loads
and minimum temperatures in the flare system to assess suitability of the existing design and what
de-pressuring controls and mitigations are required, if any.
2
The rhov values for all HP Flare drum nozzles should be confirmed as acceptable
Project should confirm that the potential for low temperatures within the flare system has been
addressed taking into account all potential modes of operation, as recommended in section 6.6.2, and
that this is reflected in the design temperatures of the flare KO Drums and stacks, particularly as it is
noted that the cold flare header from the KO drum to flare is carbon steel.
Project to confirm vacuum rating of the Cold and LP Flare KO Drums, in line with GP 44-80, 10.2.d.2.
Project to conduct a systematic review of sources to the new wet flare and existing cold flare headers
to show no potential for ice/hydrate blockage of flare headers due to mixing of cold and wet streams

or from prolonged flaring of wet streams, or if there is potential for blockage, what measures will be
taken to mitigate this.
addressed taking into account all potential modes of operation. The output from such a study should
be included within the flare and blowdown report. This equally applies to the existing cold flare header
where relocation of previous discharges to the wet flare header may adversely affect the expected
temperatures within this system, particularly as it is noted that the cold flare header from the KO drum
to flare is carbon steel.
A Safety Instrumented System summary (part of the Relief and Overpressure Protection Dossier, as
required by GP 44-70) should be prepared
The LOPA worksheets should be reviewed to establish that IL ratings have been arrived at taking
account of appropriate rule sets in the revision of GP 48-03 used as reference in the LOPA exercise.
Note also that the latest issue of GP 48-03, August 2012, has different guidance and rule sets for the
probability of failure of piping and vessels, as a function of the degree of overpressure on failure of the
protection, compared with those in the previous revision
BP GPs and all documents referenced in the LOPA report GL-WHUPZZ-SA-REP-0002_G1 LOPA
Report (Final) should have relevant revision/date noted.
Justification and an MOC audit trail should be provided in ENP-WHUPZZ-SA-REP-6652 REV B1 for
changes made to SIL ratings (all changes being reductions in IL rating) from the final LOPA report,
and for any subsequent changes arising from re-HAZOP/re-LOPA.
Check in the LOPA IL assessment that where credit is taken for trips as independent layers of
protection, they have separate output actions from the trip being assessed.
Revisit the layers of protections necessary to achieve the required risk reduction for 0230-LAHH-
1003, Wet Flare KO Drum.
Methodology used in depressuring calculations and simulations should be clearly detailed and basis
of all inputs to HYSYS defined.
Isentropic efficiency of 50% is too low for gas based systems and should be increased to 100% in
depressuring simulations.
It does not appear that minimum temperature blowdown has been considered, i.e. blowdown initiated
when system contents have cooled to minimum ambient temperature. This will give rise to the lowest
temperatures both upstream and downstream of the blowdown orifice. Depressuring scenarios for
this case should be run until atmospheric pressure is reached to ensure that lowest temperatures are
identified.


There are discrepancies in different documents regarding final blowdown pressure 6.9 barg in Flare
and Blowdown Basis of Design against 7 barg in Existing and New Depressuring Systems Verification
Report. Although this will not impact upon the depressuring rates, there should be consistency.
Design basis of flare system should be adequately documented.
Recommendation 62– Section 8.1
Project should confirm that restrictions on access to the atmospheric vent stack area and personnel
protection requirements are adequate to avoid hazard to personnel if the vent stack is ignited.
Dispersion analysis of atmospheric venting of hydrocarbons should be conducted to ensure BTX
concentrations are acceptable.
The Project should confirm what approval, if any, is necessary for the use of flame arresters for WHX.
Project to confirm maximum design rates (section 6.1.1.1) and define new flare height, to satisfy
combined flaring radiation limits, and un-ignited dispersion concentration limits.
Project to confirm that required height of the new flare has been agreed with local authorities /
regulators.
2
The Project should confirm that there is no need to adhere to radiation levels below 1.6 kW/m at the
site boundary, and document the reasons, if this cannot be achieved within new flare height
constraints.
The un-ignited dispersion analysis should include for cold blowdown towards the end of blowdown
when low flow and low temperature will give the maximum gas slumping effect.
Dispersion analysis of un-ignited venting of hydrocarbons should be conducted to ensure BTX
Confirm piping has a continuous slope back from the Cold Flare to the Cold KO Drum.
Re-design the drain arrangements for the new flare stack to avoid exposure of the operator to
hydrocarbons and potentially high levels of radiation. Confirm arrangements for draining of the Cold
and LP Flare stack risers and any required protections.
Project to review the potential for restricted flow to flare pilots/ignition system due to debris in the fuel
gas supply piping, and replace in stainless steel, as necessary.


Purge rate calculations should be prepared in line with the requirements of GP 44-80. Note that no
account can be taken for flare velocity accelerators or seals in reducing purge rates. These should
include calculation of emergency purge rates required for shrinkage due to cooling / condensation in
the flare headers, GP 44-80, 11.2.f, and including any coincident KO Drum pump-out rates.
Provide low flow alarms on fuel gas purge points, in line with GP 44-80, 11.5.l.
Confirm that back-up gas from the pipeline can be made available for flare purges/pilots following site
PSD / ESD for start-up, when on-site generated fuel gas will not be available, or, if not, provide an
alternative purge gas, in line with GP 44-80, 11.5.c.4
While cross checking the ENPPI report Appendix A1 with P&IDs it was noted that on sheet 3 of 3 of
Appendix A1 SEQ no 67 has the incorrect reference number of 0420-PSV-001B 2020. This should be
as per PI&D which shows valve as 0420-PSV-001B 2026.
The AIV report should be reviewed in order to meet the requirements of the Energy Institute and BP’s
guidance on AIV assessment. It is specifically recommended that the calculations on the detailed
assessment for the LOF using EI T2.7.3 flowchart including number of cycles are re-worked.
It is recommended that effort is spent updating the flare reports to reflect the final status,
supplementing as necessary to ensure the final deliverable(s) contain information on the points noted
in A2 of GP44-70.
It is recommended that a list of relieving devices in compiled to include the data required in A3 of
GP44-70.
A list of Removable spools should be included within the Relief and Overpressure System Dossier if
required to limit relief loads or prevent overpressure scenarios.
All calculated loads should be included within the Relief and Overpressure System Dossier with key
assumptions included as notes as necessary. Applicable calculation document numbers should be
included for reference. Refer to GP44-70 A4.
It is recommended that a list of control valves and ROs be updated in line with A5 of GP44-70. This
should include any control valve bypasses. This should include assumptions made in upstream and
downstream conditions for relief load evaluation, and should cross-reference the affected relief
device.
It is recommended that the Relief and Overpressure System Dossier contain a section on Pumps and
Compressors be compiled in line with A6 of GP44-70.
The dossier should contain a section in line with A7 of GP44-70.


Details of high integrity NRVs should be included within the Relief and Overpressure System Dossier.
It is recommended that those trips limiting relief load be incorporated in the Relief and Overpressure
System Dossier. Data recorded should be in line with A8 GP44-70.
Details of fire areas, loads etc should be incorporated within the Relief and Overpressure System
Dossier. Data recorded should be in line with A10 GP44-70.
Flare system details, including flare header, knockout drum and appurtenances, flare stack, flare tip,
igniter system, etc, should be included within the Relief and Overpressure System Dossier.
The Relief and Overpressure System Dossier should include a list of all locked closed valves which
when open would have a detrimental effect on the relief system; and all locked open valves which are
locked to provide an open path to a relief route.
It is recommended that an HP/LP interface schedule be developed in line with A13 of GP44-70.
Relief and Overpressure System Dossier should clearly state the Size and type of disposal system
used.
It is recommended that pertinent data be recorded in the Relief and Overpressure System Dossier for
PSV inlet lines.
It is recommended that a general statement regarding the mechanical design basis of the flare
headers be included within the Flare Study Report in line with note 19, para 9.4 GP44-70.

4. Compliance with ETPs and International

Standards
4.1 Applicable Engineering Standards
The following standards are applicable to the relief, flare, vent and blowdown facilities for the Project:
GP 44-70 Overpressure Protection Systems
GP 44-80 Relief Disposal and Depressurisation Systems
GP 22-20 Guidance on Practice for API 537 Flare Details
GIS 22-201 Guidance on Industry Standards for API 537 Flare Details
GN 42-010 Guidance for the Avoidance of Vibration Induced Fatigue in Process Pipework
API Std 520 Recommended Practice for the Design and Installation of Pressure Relieving
devices Parts 1 & 2
API Std 521/ ISO Guide for Relief and Depressuring Systems
23251
API RP 14C/ ISO Analysis, Design, Installation & Testing of Basic Surface Safety Systems for
10418 Offshore Production Platforms
ISO 10418 Systems for Offshore Production Platforms
ISO 28300 Venting Atmospheric and Low Pressure Storage Tanks
API Std 537 Flare Details for General Refinery and Petrochemical Service
4.2 Areas of Non-Conformance

During the verification exercise no evidence was presented to the review team to clearly demonstrate
the following areas have been studied. As such a number of areas of non-conformance with the ETPs
were identified and are noted below:
Ref Standard Paragraph Deviation Impact
1 GP 44-70 6.2a Causes of overpressure are Whilst it is realised that many of

not rigorously checked the scenarios are not applicable,
against API 521 or GN 44- a systematic approach is
001. required to ensure all relevant
cases are picked up. If not
considered, relief scenarios may
be missed leading to potential
overpressure.
GP 44-70 6.6 Reverse flow does not Relief valves grossly undersized
appear to have been in the event of check valve
considered. failure.
GP44-70 7.2 High pressure system Actual relief loads may be higher
assumed to be at normal which may lead to overpressure.
operating pressure not
maximum possible pressure.
GP 44-70 7.3 The potential to overfill the Relief device potentially

lower pressure system in the undersized for high liquid
event of failure of a letdown flowrate in the event of gas
station has not been blowby.


considered.
GP 44-70 7.4 The basis for control valve Potential for relief devices to be
Cvs used in relief undersized resulting in
calculations is not clearly overpressure.
defined. Cvs and RO Potential for control valves and
diameters which affect relief ROs to be changed without
device sizing are not investigating the impact on relief
included in a register of device.
safety critical devices.
API 521 5.10.3 Flow through bypass not Potential overpressure of low
considered in relief system pressure system when either
design when the upstream both control valve and bypass
GP44-70 7.8 pressure exceeds the open, or bypass used instead of
downstream hydrotest control valve.
pressure. Bypasses have
been locked closed instead.
GP 44-70 9.4 A comprehensive Relief and It cannot be verified that the
Overpressure System relief and flare systems are
Dossier has not been adequately designed.
prepared. Furthermore it is essential in
ensuring that future
modifications do not jeopardise
the sizing/design basis of these
critical systems.
GP 44-70 10.2.3h Backpressure exceeds 50% Relief device potentially

for a number of balanced undersized.
bellows type valves.
GP 44-70 10.2.4
GP 44-80 7.5b Radiation levels at the site Exposure of the public to

boundary have been unacceptable radiation.
calculated to be above the
limit specified.
GP 44-80 8.3.b. There is no evidence of an Potential for unmitigated

assessment of the potential blockage of flare headers
for blockage in flare headers
on mixing of cold and wet
streams.
GP 44-80 10.2c CFD analysis should be KO Drum does not meet droplet
carried out for confirmation removal requirements, burning
of liquid separation efficiency liquid rain out from flare
of the flare KO drums and for
assessment of the impact of
the inlet diverter on
separation efficiency. Not
clear that rhoV2 values of
inlet nozzles/devices have
been confirmed acceptable
GP 44-80 10.2.d.2 Vacuum rating of the Cold Design inadequate for vacuum
and LP Flare KO Drums is conditions


unclear
GP 44-80 10.3f (current It is not apparent that relief No warning given of liquid relief
version) devices on liquid relief due to either relieving condition
service discharging to the or passing valve. Potential to
flare systems are fitted with overfill flare drum.
warning devices.
GP 44-80 11.2 / 11.5 It is noted from data sheets Insufficient purge, air drawn
that purge rates are to be back into flare stacks
calculated by the flare
package supplier.
Purge rate calculations
should be prepared for
burnback prevention and
prevention of air ingress
Note that no account can be
taken for flare seals in
reducing purge rates. These
should include calculation of
emergency purge rates
required for shrinkage due to
cooling / condensation in the
flare headers, GP 44-80,
11.2.f, and including any
coincident KO Drum pump-
out rates.
GP 44-80 11.5.c4 and Purge points are not No indication of loss of gas
11.5.l provided with low flow purge and no alternative supply.
alarms and fuel gas purges
are not backed by nitrogen.
It is not apparent that he
reliability of back-up gas
supply has been confirmed
as adequate
GP 44-80 11.7e It is not apparent that the Inappropriate use of flame

use of flame arresters has arresters.
received EA (or equivalent)
approval.
Table 4.1 – Non-conformances with ETPs

5. Relief Load Verification

5.1 100% Area Checks
Using the required relief load as calculated by the design contractor and relieving conditions from the
relief valve datasheets, the required relieving area was calculated independently for each device and
compared with the size selected for installation. Any required areas calculated which would result in a
different selected orifice are summarised below. The calculations can be found in Appendix G.
5.1.1 Vapour PSVs

Of the 86 devices sized for vapour service, the required relief areas calculated for 55 of them were the
same as those determined by the project. Of those 55 valves, the appropriate orifice size was
selected for 47 of these, however, for the other 8, a G orifice has been selected where only a D is
required. These are existing valves and tabulated below. An oversized valve may lead to chattering
and subsequent valve damage and will require unnecessarily large diameter pipework which must be
sized for rated flow.
Of the remaining valves reviewed, the Atkins calculated relief area was different than the contractor’s,
either slightly larger or smaller, but the selected orifice was the same or larger. It was noted that the
selected orifice sizes stated on the datasheets for several PSVs were larger than required and that
Atkins identified inconsistencies between the relief valve datasheets and the relief calculations.
The maximum expected backpressures as stated in the “HP Blowdown System Hydraulics Verification
Report” have not been applied to the relief valve calculations (both the contractor’s and Atkins’
calculations) except for valves 0210-PSV-1028A/B and 0210-PSV-032. The correct backpressure
correction factor must be incorporated into sizing calculations to ensure that the relief valves have be
adequately sized. This has also been addressed in section 6.2.1, relief device selection.
A summary of all the valves reviewed can be found in Appendix A.

PSV Tag Equipment Protected Contractor Atkins

Required Selected Required Selected
Relief Orifice Relief Area Orifice
2 2
Area (in ) (in )
Tube side of Gas/Gas
0320-PSV-109A Exchanger (0320-HA- 0.073 G 0.073 D
001A/B)
0320-PSV-109B Exchanger (0320-HA- 0.073 G 0.073 D
001A/B)
0320-PSV-209A Exchanger (0320-HA- 0.073 G 0.073 D
002A/B)
0320-PSV-209B Exchanger (0320-HA- 0.073 G 0.073 D
002A/B)
0320-PSV-309-1A Exchanger (0320-HA- 0.086 G 0.086 D
003A/B)
0320-PSV-309-1B Exchanger (0320-HA- 0.086 G 0.086 D
003C/D)
0320-PSV-309-2A Exchanger (0320-HA- 0.086 G 0.086 D
003A/B)
0320-PSV-309-2B Exchanger (0320-HA- 0.086 G 0.086 D
003C/D)
Table 5.1 – Over-sized vapour safety valves
5.1.2 Liquid PSVs

There are 3 liquid service PSVs on the WHX project. All of these were found to be correctly sized,
however, 0210-PSV-041 and 0210-PSV-051 have two phase relief streams and therefore should be
sized and specified accordingly.
PSV Tag Equipment Contractor Atkins
Protected Required Selected Required Selected
Relief Area Orifice Relief Area Orifice
2 2
(in ) (in )
Exhaust Glycol
0390-PSV-1003 Pump D (0390-PD- 0.048 D 0.046 D
002D)
Stabilizer Reboiler
0210-PSV-041 0.471 G 0.471 G
(0210-FA-001A)
Stabilizer Reboiler
0210-PSV-051 0.471 G 0.471 G
(0210-FA-001B)
Table 5.2 –Liquid relief valves
5.1.3 Blowdown Valves
Restriction orifices were reviewed using Atkins standard spreadsheets. As can be seen from the
table in Appendix A, Atkins values are typically 20-26% greater than the values given on the
datasheets which suggest that this is due to a difference in methodology. It is therefore
recommended that RO sizing is confirmed by vendor.
RO vendor should confirm that the Project’s required rates can be achieved through supplied
orifice.

5.2 Critical Device Verification

A total of 22 critical relief devices were selected for a detailed review. This review comprised of
identifying applicable relief scenarios, evaluating relief loads for each applicable scenario and
calculating the required orifice area. The output of this analysis was then tabulated against those
scenarios and loads identified by ENPPI. The results of this work can be found in Appendix B.
5.2.1 Findings – General

In general it is felt that the relief system design is not commensurate with the maturity of the overall
facility design:
 There is no evidence that all potential overpressure scenarios have been considered in
accordance with API 521 and GN 44-001;
 A detailed review of all high pressure sources affecting a protected system does not appear to
have been undertaken, thus missing potential overpressure scenarios;
 The potential to overfill the low pressure vessel prior to gas breakthrough was not considered;
 Flow through bypasses does not appear to have been considered in accordance with GP 44-70;
 In considering flow across letdown stations, normal operating pressure appears to have been
used upstream rather than maximum possible operating pressure, typically PSHH setting;
 Relief loads on compressor discharges were based on maximum throughputs rather than data
from compressor curves;
 Calculations as presented in Existing and New Safety Valves Verification Report contain
insufficient detail, and therefore no audit trail, and are not suitable for justifying the basis for
selection and sizing of safety critical devices;
 A number of control valve Cvs are assumed or calculated. Where failure of a control valve leads
to a relief case for a downstream system, the control valve is a safety critical device. The Cv of
the installed valve must be confirmed.
As can be seen in Appendix B, from the 21 relief devices reviewed:
 For 13 devices the installed orifice predicted by Atkins was greater than that predicted by ENPPI;
 For 2 devices the installed orifice predicted by Atkins was less than that predicted by ENPPI;
 For 5 devices the installed orifice predicted by Atkins was the same as that predicted by ENPPI;
 Current orifice details for 1 device are unknown and therefore adequacy could not be
determined;
The following sections provide more detailed information on the discrepancies. It should be noted
that not all potential relief scenarios could be evaluated due to lack of data. The numbers shown in
bold italics in the following tables represent the governing case as determined by Atkins and ENPPI.

5.2.2 Findings – Undersized Devices

5.2.2.1 0210-PSV-021 A/B - Glycol/HC Separator (0210-VA-001)
0210-PSV-021A/B protects the Glycol/HC Separator, 0210-VA-001, from overpressure. It is a 1E2
valve set at 18.4 barg.
Scenarios Identified Atkins Relief Load ENPPI Relief Load ENPPI Atkins
(kg/h) (kg/h) Orifice Orifice
Fire 4127 1733
E J
Reverse Flow 8009 -
Table 5.3 – Relief Loads for Glycol/HC Separator
As can be seen from the above table, Atkins has calculated that the governing case is reverse flow
from the Ha’py Slugcatcher which was not considered by ENPPI. In addition the Atkins fire case is
greater than the ENPPI fire case. This is due to a combination of different latent heats, 535 kJ/kg
(ENPPI) versus 361 kJ/kg (Atkins), partly due to a differing methodology, and a different in the value
2 2
of wetted area used 8.8 m (ENPPI) versus 15.72 m (Atkins).
In calculating the reverse flow through the pumps we have assumed a flow area equivalent to an
orifice of 0.5 in diameter as it is a positive displacement pump.
The potential paths for reverse flow through the Condensate Recirculation Pump, 0210-PB-
001, should be reviewed and 0210-PSV-021A/B sized accordingly.
The wetted area of the Glycol/HC Separator, 0210-VA-001, should be reviewed and the fire load
updated.
5.2.2.2 0210-PSV-1005 Condensate Preheater 0210-HA-002A, Tubeside
0210-PSV-1005 protects the tubeside of the Condensate Preheater, 0210-HA-002A, from
overpressure. It is a 1D2 valve set at 17.5 barg.
Fire 830 524
Liquid Thermal Expansion N/A 1093 D E
Abnormal Heat Input 1157 -

Table 5.4 – Relief Loads for Condensate Preheater Tubeside
The ENPPI governing case for 0210-PSV-1005 is fire requiring a D orifice. The Atkins governing
case is abnormal heat input requiring an E orifice. Although abnormal heat input was considered by
ENPPI, it was considered to result in liquid expansion. However, the condensate vaporises upon the
application of heat and therefore there is a vapour relief case.
Again, there is a difference in fire load which is attributable to a difference in latent heats, 691 kJ/kg
2 2
(ENPPI) versus 370 kJ/kg (Atkins), and wetted area 0.7 m (ENPPI) versus 2.29 m (Atkins).
The orifice size of 0210-PSV-1005 should be increased from a D to an E.
5.2.2.3 0210-PSV-1006 Condensate Preheater 0210-HA-002A, Shellside
0210-PSV-1005 protects the shellside of the Condensate Preheater, 0210-HA-002A, from
overpressure. It is a 1D2 valve set at 14.9 barg.

Fire 6457 1090
E G
Tube Rupture 11,937 -
Table 5.5 – Relief Loads for Condensate Preheater Shellside
The ENPPI governing case for 0210-PSV-1006 is fire requiring a D orifice. The Atkins governing
case is also fire but requiring a G orifice.
As can be seen, there is a difference in fire load which is again attributable to a difference in latent
heats, 814 kJ/kg (ENPPI) versus 115 kJ/kg (Atkins), which is the API minimum recommended value.
Wetted areas were broadly similar.
Although tube rupture was considered by Atkins, as the shell test pressure exceeds the maximum
operating pressure of the tubeside, tube rupture does not need to be considered, although it should
be assured that the low pressure side is adequately protected.
The orifice size of 0210-PSV-1006 should be increased from an E to a G.
5.2.2.4 0210-PSV-1028A/B Condensate Stabiliser 0210-VE-001
0210-PSV-1028A/B protects the Condensate Stabiliser, 0210-VE-001, from overpressure. It is a 3K4
valve set at 9.2 barg.
Fire 5,817 12,453
Control Valve Failure -

85.65 -
0210-FV-022
Control Valve Failure -

3,538 -
0210-FV-022
Gas Blowby (vapour) 4,025 3,315

K T
Gas Blowby (Accelerated
275,229 -
Liquid)
Blocked Gas Outlet 53.5 -
Blocked Liquid Outlet 4,278 -
Liquid Overfill 19,452 -
Abnormal Heat Input 193,196 -

Table 5.6 – Relief Loads for Condensate Stabiliser
The Atkins governing case is Abnormal Heat Input where the stabiliser is shut-in with continued heat
input via the reboiler. This requires a T orifice. In addition, as the column will overfill prior to gas
blowby, the liquid will be displaced at the rate of the volumetric flow of gas entering the column which
also requires an orifice larger than the current K orifice. The difference in the calculated fire loads is
as a result of different wetted areas (8.49 m2 Atkins vs 9.9 m2 ENPPI) and different latent heats (133
kJ/kg Atkins vs 101 kJ/kg ENPPI).
5.2.2.5 0300-PSV-1024A/B Ha’py Slugcatcher 0300-VQ-001
0300-PSV-1024A/B protects the Ha’py Slugcatcher, 0300-VQ-001, from overpressure. It is a 4L6
valve set at 110 barg.

Fire (HC only) 183,989 148,146
Fire (HC+water only) 29,346 -

L M
Fire (Vapour) 12,695 -
Blocked Outlet 0.01 m3/h -

Table 5.7 – Relief Loads for Ha’py Slugcatcher
From the above table it can be seen that whilst the governing case by Atkins and ENPPI has been
identified as fire, the Atkins load is greater requiring a larger relief orifice. The reason for the
difference is assumed wetted area. Due to the length of the slugcatcher it has been assumed that
2
only that part within a fire area as defined by API 521 corresponding to an area of 232 m needs to be
considered. This is equivalent to a fire of diameter 17.2 m. Atkins have therefore assumed that a
length of 17.2 m will be subject to fire and in absence of physical details on the slugcatcher have
2
assumed that this section could be liquid full resulting in a wetted area of 400m . ENPPI have based
2
their calculations on a length of 24m and liquid level of 50% thus resulting in a wetted area of 311 m .
Whilst we consider our wetted area to be conservative and correct, the probability of accumulating
that much condensate within the system should be considered and this may result in the current
selected device being sufficient.
It is also noted that additional cases were considered such as fire under gas filled section and the
slugcatcher shut-in with continued injection of corrosion inhibitor.
Project should review the build-up of condensate within the Ha’py slugcatcher and revisit fire
relief calculations.
5.2.2.6 0320-PSV-1029A/B/C Gas/Gas Exchanger 0320-HA-001A/B Shellside
0320-PSV-1029A/B/C protect the Gas/Gas Exchanger, 0320-HA-001A/B, Shellside from
overpressure. They are 3K4 valves set at 85 and 89 barg with 2 on line.
External Fire - Vapour
34,424 29,366
Expansion
External Fire - Liquid
7,320 -
Vaporisation
Control Valve Failure 2K 2Q
(0320-FCV-103 8” bypass 802,304 -
valve)
Blocked Outlet 128,215 128,215
Table 5.8 – Relief Loads for Gas/Gas Exchanger Shellside
From the above table it can be seen that Atkins considers the governing case to be control valve
failure. Gas is fed under flow control to the LT Separator 0320-VA-001. A failure in this control
system could result in 0320-FCV-103 opening fully. Also, as the valve has a bypass this too could be
opened fully. In accordance with GP 44-70, as the maximum upstream pressure is less than the test
pressure of the vessel/exchangers, then the relief valve should be designed to pass the larger flow
between the control valve and bypass valve. In this case the bypass valve can pass considerably
more flow than the control valve and therefore becomes the governing case.
Project should consider installing a restriction orifice in 0320-FCV-103 bypass line to restrict
the flow to no greater than that which can be passed by the control valve and can be handled

by the installed relief valves. Additionally, bypass should be locked closed to ensure it cannot
be opened when the control valve is in use.
5.2.2.7 0420-PSV-801A/B HP Fuel Gas KO Drum 0420-VA-002
0420-PSV-801A/B protects the HP Fuel Gas KO Drum, 0420-VA-002, from overpressure. It is a 3K4
valve set at 40barg.
Fire - Liquid - 625
Fire – vapour expansion 1025 -
Control Valve failure

36,622 29,661
(PV201) K L

33,897 30,000
(PCV202)
Blocked Outlet 10,437 -
Table 5.9 – Relief Loads for HP Fuel Gas KO Drum
Control valve failure has been identified as the governing case by both ENPPI and Atkins. However
Atkins has identified the governing case as failure of PV201, whilst ENPPI has identified the
governing case as PCV202. No calculations are provided by ENPPI to explain how they arrived at
these figures, however with PV201 having a Cv of 37 and PCV202 having a Cv of 32 it is difficult to
see how the flow through PCV202 could be greater than that through PV201.
Differences also exist between the calculated fire loads with Atkins assuming vapour expansion and
ENPPI liquid boil-off. Finally, Atkins has also calculated a blocked outlet case.
The Cvs for 0420-PV-201 and 0420-PCV-202 should be confirmed, calculations revised and the
valve orifice size increased from a K to an L as necessary.
5.2.2.8 0420-PSV-1008A/B LP Fuel Gas KO Drum 0420-VA-001
0420-PSV-1008A/B protects the LP Fuel Gas KO Drum, 0420-VA-001, from overpressure. It is a 3L4
Fire - Liquid - 1574

19,448 7450
(PV007 + bypass)
1227 Note 1
(PV1004) K L

3921 -
(PV23A + bypass)

2303 -
(PV35B + bypass)
Blocked Outlet 1410 -
Table 5.10 – Relief Loads for LP Fuel Gas KO Drum
Note 1: Restriction orifice included in bypass such that flow through PV1004 plus bypass is no greater
than that which can be handled by an L orifice.

Failure of PV007A/B plus bypass is calculated to be the governing case. Atkins have calculated the
flow across PV007A/B as 3963 kg/hr per valve based on PAHH upstream at 78 barg. No vendor Cv
was available for this valve and the calculation has been based on a Cv of 3.07 as stated in the
2
ENPPI calculations . In addition the flow across the 1” manual bypass valve has been calculated to
be 12,932 kg/h based on a Cv of 10.6. ENPPI have calculated the flow across PV007A/B to be 2525
kg/hr per valve based on an upstream pressure of 72 barg, whilst flow through the bypass has been
calculated as 2400 kg/h based on a Cv of 3.192.
In accordance with GP 44-70, high pressure system should be assumed to be operating at maximum
possible pressure (e.g. high pressure trip setting), and therefore calculations should be based on an
upstream pressure of 78 barg.
Calculations across letdown stations should be carried out based on the maximum operating
pressure for the high pressure system, this is typically the high pressure trip setting or PSV
set pressure where no trip exists.
It is not clear where the Cv of 3.192 used to calculate the flow across the manual bypass valve
around PV007A/B has come from. Typically the Cvs of manual valves are significantly higher than
the same body size control valve.
Project should justify the use of a Cv of 3.192 for the manual bypass valve around 0420-PV-
007A/B or resort to a more typical value for a 1” manual globe valve.
Furthermore, it is noted that the Cv for PV007A/B and PV1004 has been calculated by ENPPI and are
not necessarily the installed Cvs. As the flow across these valves has a direct impact on relief device
sizing, these Cvs are safety critical and hence it is imperative that the actual installed Cv is sourced.
Project should source the installed Cv of 0420-PV-007A/B and 0420-PV-1104 and update
calculations for 0420-PSV-1008A/B as required. These Cvs are safety critical items and should
be documented as such.
5.2.2.9 0600-PSV-1006A/B Nitrogen Distribution Header
0600-PSV-1006A/B protects the Nitrogen Distribution Header from overpressure. It is a 1 ½ F2 valve
set at 10.6 barg.
Control valve failure (PCV-
2310 2000
1005A/B)
Blocked outlets 188 -
F G
Abnormal heat input HOLD – insufficient
data available to -
evaluste
Table 5.11 – Relief Loads for Nitrogen Distribution Header
Both the ENPPI and Atkins have calculated the governing case to be control valve failure of
PCV1005A/B. The derivation of the ENPPI load of 2000 kg/hr is unknown (no calculation provided)
but it is suspected that it has been calculated based on normal operating pressure upstream rather
than trip set pressure.
There will be an abnormal heat input case if the distribution system is shut-in whilst the Nitrogen back-
up heater, 0600-HM-001, remains operational. However no details on the heater dimensions are
available to evaluate this scenario.
0600-PSV-1006A/B on the Nitrogen Distribution Header should be replaced with a G orifice
valve.

5.2.2.10 0850-PSV-002A/B Water/HC Separator 0850-VA-001

0850-PSV-002A/B protects the Water/HC Separator, 0850-VA-001, from overpressure. It is a 3J4
Fire (max HC) 1286 2531
Fire (max water) 1881 504
CV Failure (0850-FCV-
193,800 -
001)
CV Failure (0300-FCV-
14,241 -
001)
Gas blowby (0850-FCV-
50,502 20,596
001) Taurt Slugcatcher
Gas blowby (0850-FCV- 1,328,433 J Q
001) Taurt Slugcatcher -
(displaced liquid)
Gas blowby (0300-FCV-
5215 13,568
001) Ha’py Slugcatcher
Gas blowby (0300-FCV- 116,047 (displaced
001) Ha’py Slugcatcher liquid)
-
Total Blocked Outlets 10,249 -

Blocked Outlet (Vapour) 40 -
Table 5.12 – Relief Loads for Water/HC Separator
Gas blowby from the Taurt Slugcatcher is the governing case for 0850-PSV-002A/B. However the
sizing basis for the relief valve is liquid displaced ahead of the breakthrough gas. As the volume of
the slugcatcher is large in comparison to the vapour space of the Water/HC Separator, the separator
will overfill before gas enters the vessel. Liquid will therefore be displaced at the volumetric flowrate
of the expanded gas.
It can also be seen that there is a large discrepancy between the gas blowby rates calculated by
Atkins and ENPPI. This is because of the different flows across the bypass. ENPPI assumed that the
restriction orifice in the bypass (0850-FO-1008) would limit the flow to 18,075 kg/h. However, at
relieving conditions this restriction orifice is calculated to pass 41,612 kg/h. It is noted that the orifice,
0850-FO-1008, has been sized on the basis of 18, 075 kg/hr of vapour at normal operating pressures
upstream and downstream. This orifice should have been sized on the maximum required liquid flow
from the slugcatcher, i.e. similar to the rate through the control valve, and then the maximum gas rate
evaluated which would be substantially less than 18,075 kg/hr. Even so it is not guaranteed that the
existing relief valve will be large enough to cope with displaced liquid.
In evaluating the flow across the control valves and orifii, the maximum upstream pressure has been
based on the high pressure trip setting. In the case of the Ha’py Slugcatcher, 0190-PSHH-003A/B on
the inlet line is set at 60 barg, whilst 0850-PSHH-006 on the inlet to the Taurt Slugcatcher is set at
110 barg. Reducing the set pressure of 0850-PSHH-006 on the Taurt Slugcatcher would reduce the
flowrates through both 0850-FCV-001 and 0850-FO-1008.
Project should consider lowering the set pressure of 0850-PSHH-006 from 110 barg such that it
provides an additional layer of protection before the Slugcatcher PSVs which also have a set
pressure of 110 barg. In addition it will reduce the relief load on 0850-PSV-002A/B on the
Water/HC Separator, 0850-VA-001.
Again, the Cvs used in our calculations have been taken from ENPPI’s Existing and New Safety
2
Valves Verification Report . Actual vendor Cv data is required to ensure that the relief device is
correctly sized.

Where control valve failure results in an ovepressure scenario it is imperative that vendor Cvs
are used in the relief device sizing calculations to ensure that the device is adequately sized.
Project should obtain Cvs for all such valves and ensure that they are reflected in the relief
calculations. These valves and associated Cvs should be documented in the Relief and
Overpressure System Dossier.
5.2.2.11 0850-PSV-1005 Water/HC Separator Condensate Outlet
0850-PSV-1005 protects the condensate train from overpressure. It is a 1 ½ G3 valve set at 17.5
barg.
Control valve failure (0850-
7567
FCV-002)
Gas Blowby (0850-FCV-
2818 2615
002)
Gas Blowby (0850-FCV- G P
135,941 (displaced
002) liquid)
Blocked outlets 3486 -
Table 5.13 – Relief Loads for Condensate Train
Whilst gas blowby is also the governing case for the sizing of this relief device, the valve is on a liquid
full system and as such Atkins has sized the valve for liquid displacement.
It should also be noted that if the downstream system is liquid full then piping could be subjected to
pressures greater than the design pressure in the event of gas blowby.
0850-PSV-1005 should be resized for liquid displacement in the event of gas blowby. In
accordance with GP 44-70 ISD principles should be applied in selecting design pressure and
corresponding set pressures for the downstream system and relief device.
5.2.2.12 0850-PSV-1023A/B Taurt Slugcatcher 0850-VQ-003
0850-PSV-1023A/B protects the Taurt Slugcatcher, 0850-VQ-001, from overpressure. It is a 4P6
Fire - liquid 11,315 -
P 6T+R
Blocked Outlet 236,484 258,283
Inadvertent valve opening 9,200,054 -
Table 5.14 – Relief Loads for Taurt Slugcatcher
ENPPI have sized 0850-PSV-1023A/B on the basis of blocked outlet. However, as the maximum
sealine pressure is 144 barg, it is possible that inadvertent opening of 0850-SDV-001 after a
shutdown, without first depressuring to the flare, could lead to very high flowrates into the slugcatcher.
It is noted that the Taurt Slugcatcher has a design pressure of 144 barg and therefore cannot be
overpressured by this scenario, but the impact on downstream systems should be considered. If this
case can be protected against by an IPS, an N orifice would suffice for all other scenarios.
Inadvertent opening of 0850-SDV-001 without depressuring and the sealine at maximum
pressure of 144 barg will result in an extremely large load. Given that this load will exceed the
capacity of the flare system, an IPS will be required. Project should review existing
overpressure protection and confirm that it is sufficiently robust and reacts quickly enough to
protect the downstream systems.
5.2.2.13 0850-PSV-1025 Methanol Storage Tank 0850-TC-003

0850-PSV-1025 protects the Methanol Storage Tank, 0850-TC-003, from overpressure. It is a 1 ½
H3 valve set at 3.5 barg.
Fire - liquid 2016 2010
Control Valve Failure
3345 -
(PCV026)
Reverse Flow - methanol 6776 - H R
Reverse Flow – displaced
1709 -
liquid
Reverse Flow - vapour 312,807 -
Table 5.15 – Relief Loads for Methanol Storage Tank
It should be noted that there was very little information available on this system and a number of
assumptions have been made. Additionally, some relief cases could not be evaluated due to lack of
data, e.g. potential for overpressuring during filling, failure of PCV-027.
ENPPI have sized 0850-PSV-1025 on the basis of fire as an H orifice. Whilst Atkins has arrived at a
similar relief load, relief valve sizing calculations based on the isentropic nozzle method have
indicated that a J orifice is required.
However, we believe that the governing case is reverse flow from the Taurt Sealine. It has been
assumed that the methanol within the injection pipework would be sufficient to overfill the vapour
space of the storage tank in the event of reverse gas flow. Initially relief would be liquid at the lower
rate of 6776 kg/hr before acceleration resulting from gas breakthrough which increases the rate to
312,807 kg/h again of liquid before finally dropping to the gas rate of 1709 kg/h.
With the exception of the ‘Reverse Flow – methanol’ case, all cases required an orifice larger than an
H.
Project should source all relevant data and review sizing of 0850-PSV-1025.
5.2.3 Findings – Oversized Relief Devices

5.2.3.1 0360-PSV-801AC/BC Onshore Gas Compressor Suction Drum 0360-VA-001C
0360-PSV-801AC/BC protects the Onshore Gas Compressor Suction Drum, 0360-VA-001C, from
overpressure. It is a 1 ½ F3 valve set at 110 barg.
Fire – Vapour Expansion 949 -
Fire – liquid (water) 697 -
F D
Fire – liquid (glycol) 903 -
Fire – liquid (condensate?) - 13,515
Table 5.16 – Relief Loads for Compressor Suction Drum
As can be seen from the above table there is a large difference in the fire loads calculated. Atkins
has calculated the highest load is as a result of vapour expansion. This case was not considered by
ENPPI and they have instead sized it on the basis of liquid boil-off. Whilst Atkins considered water
and glycol as there is no condensate present in the stream, ENNPI would appear to have assumed
condensate. However it is noted that their wetted area is very high due to an assumption of a

particularly high level in the drum, this, coupled with a very low latent heat of 48 BTU/lb, lower than
the API recommended minimum, has resulted in a large relief load and an F orifice required.
5.2.3.2 0360-PSV-1000A/B Onshore Gas Compressor HP Discharge Drum 0360-VA-

002C
0360-PSV-1000A/B protects the Onshore Gas Compressor HP Discharge Drum, 0360-VA-002C, from
overpressure. It is a 1 ½ F3 valve set at 110 barg.
Fire – Vapour Expansion 7808 -
Fire – liquid (water) 697 -
F E
Fire – liquid (glycol) 903 -
Fire – liquid (condensate?) - 9367
Table 5.17 – Relief Loads for Compressor Discharge Drum
Again, as can be seen from the above table there is a large difference in the fire loads calculated.
Atkins has calculated the highest load is as a result of vapour expansion. This case was not
considered by ENPPI and they have instead sized it on the basis of liquid boil-off. Whilst Atkins
considered water and glycol as there is no condensate present in the stream, ENNPI would appear to
have assumed condensate. However it is noted that their wetted area is higher due to an assumption
of a high level in the drum, this, coupled with a very low latent heat of 48 BTU/lb, lower than the API
recommended minimum, has resulted in a large relief load and an F orifice required.

6. Verification of Disposal Systems

6.1 Disposal System Design
6.1.1 Flare Loads
13
The Flare and Blowdown Basis of Design lists a number of scenarios to be considered. The output
of work carried out on the flare system design is presented in the Existing and New Depressuring
4
Systems Verification Report14, the HP Blowdown System Hydraulics Verification Report and the LP
3
Flare and Blowdown System Hydraulics Verification Report .
6.1.1.1 HP Flare System
There are a number of scenarios presented in the Flare and Blowdown BOD which cover a range of
potential flaring and blowdown events. The following comments are noted:
 Not all scenarios listed in the BOD have been considered in the system design;
 In the documents reviewed there is no explicit mention of the design relieving rate for the flare
system;
 Scenario 1A considers the slugcatchers blowing down from MAOP. For the Taurt slugcatcher
this has been taken as 144 barg, however the slugcatcher relief valves are set at 110 barg;
 The blowdown loads for adiabatic and fire blowdown for each blowdown section are identical;
 GP 44-80 requires the emergency depressuring load be added to the largest relief load that
could be the cause of need to depressurise to account for simultaneous relief and blowdown.
This does not appear to have been considered;
 Emergency depressuring/relief coincident with operational flaring does not appear to have been
considered;
 In general only blowdown loads have been considered. No allowance has been made for relief in
the event of common mode failures, e.g. instrument air failure, power failure.
Project should confirm that the flare design has considered all coincident flaring cases.
Project should produce a comprehensive Relief, Flare and Blowdown Report which clearly
identifies and justifies the design basis for each of the flare systems. This report should also
contain the output of any supplementary studies, e.g. low temperature, ice/hydrates, or as a
minimum reference these.
6.1.1.2 LP Flare System
There are a number of scenarios presented in the Flare and Blowdown BOD which cover a range of
potential flaring and blowdown events. The following comments are noted:
 There are a number of identified scenarios which exceed the existing design capacity of the flare
system, 2500 kg/h. It is noted that the flare tip vendor has confirmed that the tip can be rerated
to 7600 kg/h.
If the LP Flare system capacity has been rerated it should be clearly stated as such. It should
also be confirmed that the flare system in its entirety is good for the higher rate and not just
the flare tip.
 A number of loads listed in the hydraulics verification report are noted as having come from the
FEED study.
Confirm that loads based on FEED design are still valid.

6.2 Relief Device Selection

Relief devices should be appropriately selected for their respective duties. Issues such as back-
pressure limitations, fluid phase and speed of response have been reviewed for the relief devices on
the West Harbor Expansion Project. Design pressure and temperatures of the valves were not
provided and therefore have not been assessed.
The maximum and minimum project design pressure and temperatures should be reviewed
against valve design pressure and temperature, and valves confirmed acceptable.
Datasheets for existing valves have not been provided. Project should confirm that the
existing valves have been reviewed and are suitable for new conditions.
6.2.1 Backpressure limitations

The following sections consider the backpressure limitations for differing types of relief device. As
identified in section 5.1 there was a discrepancy between the backpressures listed on the PSV
datasheets and those used in the calculations and these should be reviewed. The HP Blowdown
4
System Hydraulics Report confirms the maximum superimposed and built-up backpressures
expected at each PSV. These backpressures are significant and have not been used in the PSV
sizing calculations. Backpressure has a significant effect on the sizing of balanced bellows and pilot
operated valves and a backpressure correction factor must be applied, even if the backpressure is
due to a scenario in which the relief valve is not operating (GP 44-70 10.2.3i).
6.2.1.1 Conventional Relief Valves
Built-up backpressure opposes the lifting force which holds a conventional valve open. Conventional
valves should only be used in systems where built-up backpressure is less than 10% of the set
pressure. The built up back pressures were taken from the HP Blowdown System Hydraulics
4
verification report , for most valves. All the backpressures for conventional valves fell within this limit.
0850-PSV-002A/B has been specified with a set pressure of 40 barg but a variable superimposed
backpressure of 6.4 barg is expected. Use of a conventional valve is not advisable where a significant
variable superimposed backpressure is expected, a balanced valve should be considered.
Back pressures for conventional relief valves should be updated on PSV datasheets.
6.2.1.2 Balanced Relief Valves
Balanced bellows relief valves are suitable for use in systems where built-up backpressure is too high
for conventional relief valves. Total backpressure (built-up plus superimposed) must not exceed 50%
5
of the relief valve set pressure as stated in GP 44-70 . Again no built-up back pressure was specified
on the datasheets and this should be reviewed. However, the BUBP for most valves were given in the
4
HP Blowdown System Hydraulics verification report .
The PSVs on the stabiliser column reboiler (0210-PSV-041/051) the total back pressure is 60% of the
set pressure. However, as the back pressure is largely constant super imposed back pressure it was
deemed acceptable and it is assumed that the valve spring will be adjusted to cater for this constant
back pressure.
The built up back pressures for all balanced relief valves should be calculated and the
datasheets updated.
The back pressures acting on 0210-PSV-012A/B, 0210-PSV-032, 0210-PSV-1006, 0210-PSV-
1007 and 0320-PSV-1027A/B should be reviewed.
For several of the existing and new balanced bellows valves, the expected total backpressure is in
excess of what is acceptable, 50% of the set pressure. These are tabulated below and the
manufacturer should be consulted to ensure that operation of these valves will be effective under the
worst backpressure conditions. The appropriate backpressure correction factor must be incorporated
into the sizing calculation or the valve will be undersized.
PSV Tag PS Constant Variable Built-up PB PB/PS

(barg) Superimposed Superimposed Backpressure (%)
Backpressure Backpressure (bar)
(barg) (barg)
0210-PSV-
15.0 0.5 7.16 2.38 9.54 64%
012A
0210-PSV-
15.0 0.5 7.16 2.38 9.54 64%
012B
0210-PSV-
9.2 0.5 7.16 1 8.16 89%
032
0210-PSV-
14.5 0.5 7.16 0.85 8.01 55%
1006
0210-PSV-
14.5 0.5 7.16 0.87 8.03 55%
1007
0320-PSV-
17.5 0.5 7.4 2 9.4 54%
1027A
0320-PSV-
17.5 0.5 7.4 2 9.4 54%
1027B
Table 6.1 – Balanced bellows valves exceeding backpressure allowance
The back pressures for all PSVs should be confirmed and PSV datasheets, calculations and
sizing verification report updated accordingly.
Appropriate backpressure correction factors should be incorporated into the sizing
calculations for balanced bellows and pilot operated valves where required.
Confirm with manufacturer that the backpressures expected are acceptable for adequate
operation of the specified relief valves.
6.2.1.3 Pilot Operated Relief Valves
Valve lift is not affected by backpressure and so pilot operated relief valves can be used in relief
systems with backpressures exceeding 50% of the set pressure. Again built up back pressures have
not been specified on datasheets or in the calculations given, but are outlined in HP Blowdown
System Hydraulics Report (ENP-WHUPZZ-PR-REP-1060-D3).
The worst case back pressures for all pilot operated relief valves should be confirmed and the
datasheets and calculations updated.
6.2.2 Service
All valves are specified depending upon the service – safety for vapour relief, relief for liquid relief and
safety-relief for multi-phase relief. As little information was provided about the other relief scenarios
aside from the sizing case it was difficult to assess this criteria. However, as can be seen from Atkins
calculations for critical devices there are a number of valves which would have to operate for different
fluid phases. Whilst relief valves can adequately handle liquid, the reverse is not true and safety
valves will have to be derated when used for liquid service. For existing valves no information has
been provided on the type of service required.
PSVs 0320-PSV-1030A/C are on the shell side of heat exchanger 0320-HA-002A/B and have been
specified as safety valves, and 0320-PSV-1030B has been specified as safety relief. Despite being
sized for blockage, if a tube rupture occurred the valve would need to handle some 2 phase flow as
glycol is being injected upstream of the heat exchanger.
PSVs 0320-PSV-1030A/C should be specified as safety relief valves and that ethylene glycol is
will be present under some relieving conditions.
Project should review and confirm that all relief devices have been appropriately selected to
function adequately across all potential relief scenarios. Where safety valves are expected to
be used to relieve liquid under certain scenarios, the valve capacity should be reviewed and
confirmed as acceptable with derating factor applied.

6.2.3 Speed of Response

Through the course of review speed of response was not thought to be an issue other than for 0850-
PSV-1005 on the condensate outlet of the Water/HC Separator where gas can breakthrough into a
liquid filled system. Transient pressure increase can be rapid with the potential to exceed the design
pressure. Refer to Section 5.2.2.11.
6.2.4 Multiple Relief Valves

Dual PSVs with staggered set points have been specified for the shell side of the LTS gas/gas
exchangers and the HP discharge coolers. There were the following inconsistencies between
calculations and PSV datasheets:
 The accumulation percentage used in the sizing calculation for 0320-PSV-1030B was 16% and
is listed as 10.48% on the datasheet.
 The datasheet for safety valve 0360-PSV-831AC/BC/CC states that PSV-831BC has a set
pressure of 115.5 barg, which is not shown anywhere in the sizing calculation.
Update calculations so they are consistent with data listed on the datasheets.

6.2.5 Design Temperature

Design temperatures for new and existing relief devices were not provided and consequently
adequacy cannot be confirmed. Refer to recommendation in Section 6.2.
6.3 Relief Device Inlet Piping

Relief device inlet piping must be designed for intended device performance.
6.3.1 Drainage and Blockages

The inlet line size and block valve size (if present) were listed for each critical relief valve along with
the relief device inlet flange size. All inlet lines and block valve sizes are equal to or larger than the
relief valve inlet flange.
The isometric piping drawings for each critical PSV were reviewed where available to ensure
adequate drainage away from the relief device is provided. It was found that all of the inlet lines do not
meet the minimum slope requirement of 1:400.
See Appendix C for further details.
Project should confirm that all critical device inlet lines meet the minimum slope of 1:400.
6.3.2 Inlet Pressure Drop

6
For existing valves the inlet line pressure loss must not exceed 7% of set pressure and new valves
shall not exceed 3%, at the relief valve’s rated flow. A pressure drop calculation was completed for
each critical relief valve. Fluid properties were taken from the Existing PSV’s Upstream Line Sizing
Verification Report (ENP-WHUPZZ-PR-REP-1055-G3), or from the HYSYS file with a similar
molecular weight to that used in the original PSV sizing calculation. A summary of the pressure drops
is shown in Appendix C.
Of the 21 critical valves, 6 had inlet line losses over 3% of set pressure. Two of these, 0420-PSV-
801A/B and 0850-PSV-1023, were existing valves and were less than 7%. The table below
summarises the valves with a pressure drop outside of project specifications.
Atkins
Pressure
PSV Tag Existing/New Type Drop (% of
set
pressure)
0210 PSV 1028A/B New Pilot 10.2%
0210 PSV 1005 New Balanced Bellows 3.0%
0420 PSV 1008A/B Existing Pilot 8.4%
0600 PSV 1006A/B New Conventional 7.9%
0850 PSV 1025 Existing Conventional 7.9%

Table 6.2 - Critical PSV’s with Inlet line pressure drop outside acceptable limits
For the pilot operated valves in Table 6.2, a subsequent pressure drop calculation was completed
7
with the required relief flow, rather than the rated flow, in line with API RP 520 . However, the inlet line
pressure drop remained above 7% for these valves. It is not clear if these pilot valves will have remote
sensors from information provided on datasheets. If these are required datasheets should be updated
to include this information.

The piping configuration for the inlet lines to 0210-PSV-1028A/B, 0210-PSV-1005, 0420-PSV-
1008A/B, 0600-PSV-1006A/B and 0850-PSV-1025 to ensure the pressure drop as a percentage
of set pressure is below the required project limits.
Confirm if the pilot operated valves require remote sensors and update datasheets
accordingly.
6.3.3 Winterisation
8 6
The minimum ambient design temperature is 5⁰C thus heat tracing for Winterisation is not expected .
Philosophy requires that heat tracing is provided on lines where stagnant flow may be conducive to
ice or hydrate formation. On reviewing the P+IDs it is not apparent that heat tracing has been applied
to any PSV inlet lines or critical instrument impulse lines.
Project should confirm that the potential for blockage of the PSV inlet lines and impulse lines
due to hydrate formation has been considered and appropriate measures are in place.
6.4 Relief Device Tailpipes and Flare Headers

6.4.1 Flare Model
9
A model has been constructed for Wet HP Flare Systems using Aspen Flare System Analyser .
Models for the Cold Flare and LP Flare were not presented for review. Model constraints are as
follows:
Constraints Header Tail Pipes
Noise 155dB 155dB

Mach No. 0.8 0.8
Table 6.3 - Flare model constraints
Roughness factors used in the model are 0.15mm for carbon steel pipe and 0.046mm for stainless
steel pipe in line with GP 44-80.
The HP wet flare model was reviewed and the findings can be found in Appendix F. The model of the
HP Wet Flare Header for the WHX Project does not reflect information from PSV sizing calculations or
2
isometrics. The relief loads for all new and existing PSVs were checked against calculation data and
there were many inconsistencies in relation to rated and required relief flowrates, set pressures and
accumulation. However, no PSVs have been run in any of the flare scenarios. There are also
discrepancies between the isometrics (see Proforma 6.0) and P&IDs in terms of pipework routing,
lengths and location of tie in points.
It should be noted that the flarenet model is Rev D2, and the HP Blowdown System Hydraulic
Verification Report of the same document number is Rev D3, which could be the reason the data
does not match.
The flare model should be updated to provide an accurate model of the network in order to
size headers and sub headers correctly and evaluate the back pressures within the system.
All error messages in the flarenet model which have been flagged up should be resolved.
6.5 Liquids Handling

6.5.1 Piping
No stress analysis documentation was presented for review. The piping should be designed to ASME
B31-3 and stress analysis should consider the effects of shock loading (liquid hammer due to liquid
entrained in two phase flow) in systems that may nominally have been designed for vapour handling

only. The possibility of liquid entrainment is particularly acute in lines downstream of relief valves so
the operation of such lines/valves should be carefully considered and the effects of liquid shock
loading included in stress analysis if required. It is important that all relief valves which may see liquid
or two phase relief are screened and not just those where these conditions exist as the governing
10
case. It is noted that the line list does not note those lines which could be subjected to two phase
flow, although, certainly in some cases, there is a note to reflect this on the P+ID.
It should be confirmed that the piping systems associated with those relief valves which may
see multi-phase relief are noted as such on the line list and subjected to screening and, if
required, full stress analysis.
6.5.2 Flare Knock Out Drums

Verification reports and sizing calculations have been provided for the new Wet HP Flare and existing
LP Flare KO Drums, ENP-WHUPZZ-PR-REP-1057, G2 and ENP-WHUPZZ-PR-REP-1065, B2. The
KO Drum sizing methodology has been reviewed and is suitable. However, it is not clear where the
source data for the calculations for each of the cases considered; flowrates, densities of vapour and
liquid have been drawn from. In addition, the volume in the LP Drum should be sufficient to satisfy
GP44-80 requirements for liquid hold-up, for overfill from the water/HC and glycol/HC separators, a
liquid load identified in the LOPA report. It is not clear that this has been considered.
Reference should be made in the Wet HP and LP Flare KO Drums verification reports, and
associated calculations, to the documents from which the source data was drawn – flowrates,
densities and viscosities. The flowrates and the derivation of these for the varying sizing
cases should also be detailed in the Flare and Blowdown BOD document, and the Existing &
New De-pressuring Systems Verification Report ENP-WHUPZZ-PR-REP-1050, G1.
If, following response to the recommendations in section 6.1.1.1, the design flowrates are
amended, the KO Drum sizing will have to be re-evaluated.
There is an overfill case for the LP flare KO Drum from the water/HC and glycol/HC separators,
as included in the LOPA report. Project should confirm that this has been considered in
confirming that the liquid surge volume in the LP Drum conforms with the requirements of GP
44-80.
An inlet diverter is to be provided on the inlet stream to the Wet Flare KO Drum.
CFD analysis is required for confirmation of liquid separation efficiency of the flare KO drums
and for assessment of the impact of the inlet diverter on separation, in line with 10.2.c of GP
44-80.
It is not clear whether incoming / outgoing gas pipelines will be de-pressured through the HP Flare
system. If so, this will introduce the potential for high flowrates, liquid loads and low temperatures in
the Flare KO Drums.
Project to confirm if there is an intention for incoming / outgoing gas pipeline to be de-
pressured through the flare system and if this is intended, quantify maximum de-pressuring
rates, liquid loads and minimum temperatures in the flare system to assess suitability of the
existing design and what de-pressuring controls and mitigations are required, if any.
The rhov2 values for all HP Flare drum nozzles should be confirmed as acceptable.
KO Drum pump out arrangements are adequate to pump out from maximum liquid level to normal
liquid level in 2 hours.
No minimum temperature reports were available to enable verification of the design temperatures of
KO Drums.
addressed taking into account all potential modes of operation, as recommended in section

6.6.2, and that this is reflected in the design temperatures of the flare KO Drums and stacks,
particularly as it is noted that the cold flare header from the KO drum to flare is carbon steel.
The LP and Cold Flare KO Drums are not noted on the relevant P+IDs as being designed for full or
half vacuum, as required by GP 44-80, 10.2.d.2.
Project to confirm vacuum rating of the Cold and LP Flare KO Drums, in line with GP 44-80,
10.2.d.2.
6.6 Design and Construction

6.6.1 Relief Segregation
There is no evidence of an assessment of the potential for blockage in flare headers on mixing of cold
and wet streams, as required by GP 44-80, 8.3.b. It is noted that cold blowdown and wet headers join
before entry to the Wet Flare KO Drum. Also, due to constraints on capacity, indicated in ENP-
WHUPZZ-PR-REP-1027, D1 Flare Radiation VR, some streams which were to be routed to the New
Wet Flare KO Drum appear to have been re-directed into the existing cold flare.
Project to conduct a systematic review of sources to the new wet flare and existing cold flare
headers to show no potential for ice/hydrate blockage of flare headers due to mixing of cold
and wet streams or from prolonged flaring of wet streams, or if there is potential for blockage,
what measures will be taken to mitigate this.
6.6.2 Low Temperature Relief

o
There are three HP Wet Flare headers: one carbon steel with a design temperature of -29 C, one low
o
temperature carbon steel (LTCS) with a design temperature of -46 C and the other stainless steel with
o
a design temperature of -98 C. In addition there is a blowdown collection header in LTCS. The
headers combine prior to entering the HP Wet Flare KO Drum into a single LTCS 36” line. It is noted
that there is a note on the P+ID which states that LTCS must be extended at least 10m into the CS
line in accordance with GP44-80.
14
Whilst the Depressuring Systems Report states the temperatures downstream of the blowdown
orifice, it does not state temperatures immediately downstream of PSVs or PCVs entering the flare
system. Additionally it is presumed that the temperatures given are based on adiabatic blowdown
and not minimum temperature blowdown. Finally, the temperature within the flare system is not noted
for the different scenarios.
addressed taking into account all potential modes of operation. The output from such a study
should be included within the flare and blowdown report. This equally applies to the existing
cold flare header where relocation of previous discharges to the wet flare header may
adversely affect the expected temperatures within this system, particularly as it is noted that
the cold flare header from the KO drum to flare is carbon steel.
6.6.3 Facilities for Drainage

The relief disposal system should be designed to prevent the accumulation of liquids in low points or
pockets. The flare system piping should be designed to incorporate adequate slopes away from the
relief device and into the header system. Laterals from individual relieving devices should normally
enter the header from above to minimise the likelihood of liquid entry to the laterals.
The isometric drawings for the tailpipe of each critical relief device, sub-headers and headers were
reviewed to ensure that drainage is adequate. It was found that
 Slopes are inadequate:
- Relief device tailpipes slope to the sub-header does not always meet the 1 in 400 criteria
and in some sections lines are horizontal;

- The sub-headers slope to the headers does not always meet the 1 in 400 criteria;
- The headers slope to the knock-out drums does not always meet the 1 in 400 criteria;
 Relief valve tailpipes enter the sub-headers from above;
 Relief valve tailpipes enter the sub-headers at an angle of approximately 45°;
 No pockets in line.
A comprehensive review of all critical relief device tailpipes, sub-headers and headers can be found in
Appendix E.
It should be noted that there are some instances where the slope is not stated on the isometric
drawing and where the isometric drawings are unavailable.
6.6.4 Facilities for Isolation

Where several units are connected to one discharge system it is common practice to provide isolation
valves in the sub headers at battery limits. These valves must have reliable locking mechanism and
spectacle blinds upstream, and be of a type and mounted so that mechanical failure of the valve
cannot restrict or block the relief flow path. A valved blanked drain branch should be provided
upstream of the isolating valve to allow for draining/purging of the isolated sub header.
West Harbor has no sub-header isolation but there is a full bore CSO ball valve downstream of each
entry to the flare system with a blanked drain/vent connection upstream. This will allow some degree
of isolation for maintenance and shut-down.
In light of the above, isolation is considered acceptable.
6.6.5 Structural Supports

No piping support design was available for review. In general, the piping supports should be designed
to withstand all operational loads such as dead and thermal loads applied from the piping as well as
environmental loads such as wave, wind and seismic events. It should be noted that during blowdown
events, rapid cooling of the piping could lead to thermal stresses significantly in excess of those
experienced during a standard ambient to design thermal load case.

7. Emergency Shutdown and Depressurisation

7.1 Emergency Shutdown
There are five levels of shutdown in the West Harbor facilities ranging from Unit Shutdown to full site
Emergency Shutdown. A high level overview describing the initiators and the trips is given in the
11
Emergency Shutdown (ESD) Philosophy . The facilities have been divided into three blowdown
sections based on geographical layout:
Section 1: Slugcatchers, Separators and Produced Water Treatment;
Section 2: Existing Gas Compression, LTS and existing HC Liquids handling;
Section 3: West Harbor Expansion new equipment.
Although sectionalised, the flare system has been designed to handle simultaneous blowdown of all
three sections. Confirmed fire within one of the three sections will result in a facilities Emergency
Shutdown (ESD) which will shutdown and automatically depressure the facilities. In addition a
facilities ESD can be initiated by a pushbutton on the ESD panel.
Additionally, blowdown of each section can be manually initiated by pushbutton on the ESD panel
which will also initiate a Process Shutdown (PSD) of the entire site.
A PSD can also be initiated by confirmed gas detection, excursion of key process parameters or a
manual pushbutton on the ESD panel. This will shutdown all facilities and blowdown the compression
trains. In addition there are three individual PSDs, Ha’py PSD, Taurt PSD and Common Facilities
PSD, again initiated by manual pushbutton or excursion of key process parameters.
Finally there are a number of Unit Shutdowns (USD) which automatically trip on excursion of key
process parameters.
7.2 Instrument Protections

The Project has not provided a Safety Instrumented System summary (part of the Relief and
Overpressure Protection Dossier, as required by GP 44-70)
A Safety Instrumented System summary (part of the Relief and Overpressure Protection
Dossier, as required by GP 44-70) should be prepared.
A LOPA has been carried out in line with GP 48-03 by the same team carrying out the Execute
HAZOP and during the course of the HAZOP.
Project has provided GL-WHUPZZ-SA-REP-0002_G1 LOPA Report (Final), It is noted that TRAC has
not been used to record discussion and quantify IL ratings required in this report. It is also noted that
the appropriate rule sets in the prevailing 2008 revision of GP 48-03 for degree of overpressure vs
probability of loss of containment and for probability of ignition do not appear to have been
consistently applied across the worksheets and that ignition probabilities used in the assessments
appear to apply to offshore, not onshore facilities, in some cases conservative, in others optimistic.
Also, references to BP GPs in the LOPA report do not show the revision/date of issue of those GPs.
Some process areas were excluded from the HAZOP and LOPA due to lack of documentation,
namely, produced water and waste water treatment, instrument air and nitrogen systems. Also the
cold vent was excluded from the scope as it was known to be undersized.
The LOPA worksheets should be revisited to establish that IL ratings have been arrived at
taking account of appropriate rule sets in the revision of GP 48-03 used as the reference
document in the LOPA exercise. Note also that the latest issue of GP 48-03, August 2012, has
different guidance and rule sets for the probability of failure of piping and vessels, as a
function of the degree of overpressure on failure of the protection, compared with those in the
previous revision.

Project to confirm that HAZOP and LOPA will be carried out on, produced water and waste
water treatment, instrument air and nitrogen systems and the cold vent when re-designed to
cater for the required loads.
BP GPs and all documents referenced in the LOPA report GL-WHUPZZ-SA-REP-0002_G1
LOPA Report (Final) should have relevant revision/date noted.
The SIL verification report, ENP-WHUPZZ-SA-REP-6652 REV B1, has amended some IL ratings, but
without full documentation of the justification for change.
Justification and an MOC audit trail should be provided in ENP-WHUPZZ-SA-REP-6652 REV B1
for changes made to SIL ratings (all changes noted as being reductions in IL rating) from the
final LOPA report, and for any subsequent changes arising from re-HAZOP/re-LOPA.
For 0360-LALL-612A and 0360-LALL-602A (P) and (V), credit is taken for 0210-PAHH-041 and 0360-
PSV-812A/B in reducing the IL requirement. Credit for the PSV is based on its sizing for gas blowby,
but liquid relief at gas blowby volumetric rates will precede gas relief.
Project to confirm whether 0360-PSV-812A/B is sized for liquid relief under gas blowby
conditions and therefore if credit can be taken for it as a protection layer for 0360-LALL-612A
and 0360-LALL-602A (P) and (V).
Project to confirm whether 0210-PAHH-041 acts on different output devices compared with
0360-LALL-612A and 0360-LALL-602A (P) and (V), and therefore if credit can be taken for
PAHH-041 as a protection layer.
For 0360-LALL-612C and 0360-LALL-602C, (1), (2) and (3), credit is taken for 0850-PAHH-002 in
reducing the IL requirement. Credit for the PSV is based on its sizing for gas blowby, but liquid relief
at gas blowby volumetric rates will precede gas relief.
Project to confirm whether 0360-PSV-812A/B is sized for liquid relief under gas blowby
conditions and therefore if credit can be taken for it as a protection layer for 0360-LALL-612A
and 0360-LALL-602A (P) and (V).
It was noted that in assessing the IL rating for 0230-LAHH-1003, Wet Flare KO Drum, credit has been
taken for the slugcatcher high level trip in calculating the mitigated event likelihood. According to C&E
ENP-WHUPZZ-PR-CED-1085, Appendix A, both the flare KO drum and slugcatcher cause PSD, so
the slugcatcher trip is not an independent layer of protection. While slugcatcher overfill is not the
dominant cause in setting the IL rating, the credit taken for the slugcatcher trip should be reviewed.
This may also imply that a check should be made that appropriate credit for trips has been taken for
the other trips assessed in the LOPA, particularly for the LP Flare and Cold KO Drums.
Check in the LOPA IL assessment of trip loops, in particular the high level trips in the flare KO
drums, that where credit is taken for other trips as independent layers of protection, these
other trips do have separate inputs, logic and output actions from the trip being assessed,
and, if not, revise the LOPA accordingly, for example, credit wrongly taken for slugcatcher
high level trip as an independent layer of protection for the high level trip in the Wet Flare KO
Drum, and credit taken for 0210-PAHH-1012/1013 in closing upstream sources, as a layer of
protection in the LOPA for PAHH-0210HA002.
A recommendation in ENP-WHUPZZ-SA-REP-6652 REV B1, is to provide a separate high level alarm
for the Wet Flare KO Drum, since the required IL rating for 0230-LAHH-1003 cannot be achieved.
This cannot be considered as a separate protection layer since there is already credit taken for
operator response to the existing alarm 0230-LAH-1001 in the LOPA assessment.
Revisit the layers of protections necessary to achieve the required risk reduction for 0230-
LAHH-1003, Wet Flare KO Drum, since credit is taken twice for operator intervention, which
indicates a lack of understanding of the principles of LOPA and the requirements of GP 48-03.

It is noted that in the LOPA for 0210-LAHH-032, the output device of the trip is control valve FV-022.
While no credit has been taken for the trip if the control loop LIC-035 drives FV-022 open, if this valve
fails open/stuck, as a cause of rising level, then there will be no high level trip protection. Use of a
control valve as a shutdown valve is, in any case, not good practice.
Project to review feasibility of actuating a separate on/off valve, rather than FV-022 as the
output device of trip loop 0210-LAHH-032.
A number of assumptions are made in the LOPA report under an Assumptions heading and some
actions are contained under Summary of Recommendations for Action, and in the text in the
LOPA worksheets, for example for 0210-PAHH-1012-1014. It is noted that there appears to be no
relief protection associated with 0210-PAHH-1012-1014 and that this is alluded to in one of the LOPA
actions, action 3.
Project to confirm that assumptions made in the LOPA report under an Assumptions heading
are valid, and that the actions contained under Summary of Recommendations for Action, and
in the text in the LOPA worksheets, for example for 0210-PAHH-1012-1014, are being captured
and closed out in the project Action Tracking System.
In particular, project to confirm that relief or other protection will be provided on the
condensate pre-heaters and downstream glycol/HC separator for gas blowby/liquid relief, and
for a blocked outlet case, in support of 0210-PAHH-1012/1013 (PSVs sized for fire case).
7.3 Emergency Depressurisation

7.3.1 Philosophy
12
The requirements for depressuring are presented in the Flare, Blowdown and Vent Philosophy . An
emergency shutdown will result in immediate isolation and blowdown of the facilities as will confirmed
fire in process areas. The basis for the facilities is to blowdown to 7 barg in 15 minutes for vessels
less than 1 inch wall thickness and to blow down to less than 50% of design pressure in 15 minutes in
the event of a fire for those systems with wall thicknesses greater than 1 inch.
7.3.2 Methodology
There is no detailed methodology given in any of the documents reviewed: Flare, Blowdown and Vent
12 13
Philosophy , Flare and Blowdown Basis of Design and Existing and New Depressuring Systems
14
Verification Report . Additionally neither HYSYS depressuring models nor depressuring calculations,
although requested, have been received for review.
However, based on the documents reviewed as noted, the following is inferred:
 HYSYS depressuring module has been used to simulate blowdown;
 For fire cases starting pressure is assumed to be design pressure (maximum settle-out pressure
for compressors) and maximum operating temperature coincident with maximum ambient
o
temperature of 40 C;
 For adiabatic blowdown starting pressure is again assumed to be design pressure (maximum
settle-out pressure for compressors) and minimum operating temperature coincident with
o
minimum ambient temperature of 5 C. An isentropic efficiency of 50% is applied.
7.3.3 Review of Depressurisation

 Methodology used in depressuring calculations and simulations should be clearly
detailed and basis of all inputs to HYSYS defined.
 Isentropic efficiency of 50% is too low for gas based systems and should be increased to
100% in depressuring simulations.

 It does not appear that minimum temperature blowdown has been considered, i.e.
blowdown initiated when system contents have cooled to minimum ambient temperature.
This will give rise to the lowest temperatures both upstream and downstream of the
blowdown orifice. Depressuring scenarios for this case should be run until atmospheric
pressure is reached to ensure that lowest temperatures are identified.
 There are discrepancies in different documents regarding final blowdown pressure 6.9
barg in Flare and Blowdown Basis of Design against 7 barg in Existing and New
Depressuring Systems Verification Report. Although this will not impact upon the
depressuring rates, there should be consistency.
 Design basis of flare system should be adequately documented.

8. Flare Stacks and Atmospheric Vent Stack

8.1 Atmospheric Vents
The atmospheric vent register is not available for review.
Dispersion and radiation analysis has been carried out for the atmospheric vent stack. If ignited, flame
impingement at grade and certainly at working height is possible, with attendant hazard to operators.
Project should confirm that restrictions on access to the atmospheric vent stack area and
personnel protection requirements are adequate to avoid hazard to personnel if the vent stack
is ignited.
Dispersion analysis of atmospheric venting of hydrocarbons should be conducted to ensure
BTX concentrations are acceptable.
The atmospheric vent is fitted with a flame arrester, the fitting of which requires entity EA approval in
accordance with GP 44-80.
The Project should confirm what approval, if any, is necessary for the use of flame arresters
for WHX.
8.2 Flare Stacks

Radiation calculations have been performed, ENP-WHUPZZ-PR-REP-1027, D1. These show
acceptable radiation levels on-site in line with the criteria required by GP 44-80, with less than 4.73
2 2
kW/m at the edge of the sterile area and less than 3.2 kW/m at the nearest location where personnel
may normally be working. Radiation at the boundary exceed s 1.6 kW/m2, though statements made
that this is considered acceptable, reasons should be documented. Further it is not clear from ENP-
WHUPZZ-PR-REP-1027, D1, Flare Radiation VR, that the flare stack height has been fixed and
agreed with local regulators. There appears to be much work still required to define maximum rates
for design (see section 6.1.1.1), flare height, flare radiation, for combined flaring, and un-ignited
dispersion.
Project to confirm maximum design rates (section 6.1.1.1) and define new flare height, to
satisfy combined flaring radiation limits, and un-ignited dispersion concentration limits.
Project to confirm that required height of the new flare has been agreed with local authorities /
regulators.
The Project should confirm that there is no need to adhere to radiation levels below 1.6 kW/m2
at the site boundary, and document the reasons, if this cannot be achieved within new flare
height constraints.
Unignited dispersion analysis has been carried out for low flows, in line with Annex A of GP 44-80, but
these are unlikely to represent the worst case, which is likely to be at a much lower and colder flow
towards the end of blowdown, when slumping of gas could be expected.
The un-ignited dispersion analysis should include for cold blowdown towards the end of
blowdown when low flow and low temperature will give the maximum gas slumping effect.
Dispersion analysis of un-ignited venting of hydrocarbons should be conducted to ensure BTX
No slope is shown on the flare line to the Cold Flare stack.
Confirm piping has a continuous slope back from the Cold Flare to the Cold KO Drum.
Flare ignition arrangements are diverse and the flare can be re-lit remotely, so that an operator does
not have to approach a potential gas cloud to re-ignite the flare.

It is noted that the design intent to dispose of any liquid collecting at the base of the new flare stack,
including following blowdown, is to manually drain this to a portable container. This will not only
expose the operator to hazardous release of hydrocarbon but may also lead to exposure to high
levels of radiation on approach to the flare stack.
Re-design the drain arrangements for the new flare stack to avoid exposure of the operator to
hydrocarbons and potentially high levels of radiation. Confirm arrangements for draining of
the Cold and LP Flare stack risers and any required protections.
The fuel gas supply to the new flare is in carbon steel. There is no filtration on this fuel gas supply and
there is risk of restricted flow/blockage to pilots and the ignition system if there is debris / corrosion
product in this line.
Project to review the potential for restricted flow to flare pilots/ignition system due to debris in
the fuel gas supply piping, and replace in stainless steel, as necessary.
8.3 Flare Purges and Flashback Prevention

Purge rate calculations have not been made available by Project. It is noted from data sheets that
purge rates are to be calculated by the flare package supplier.
Purge rate calculations should be prepared in line with the requirements of GP 44-80. Note that
no account can be taken for flare velocity accelerators or seals in reducing purge rates. These
should include calculation of emergency purge rates required for shrinkage due to cooling /
condensation in the flare headers, GP 44-80, 11.2.f, and including any coincident KO Drum
pump-out rates.
Purge points are not provided with low flow alarms and fuel gas purges are not backed by nitrogen.
However, there is back-up to the on-site generation of fuel gas, by import from the gas pipeline, but it
is not clear from the Cause and Effects supplied if this supply can be made available on shutdown of
the site, either PSD or ESD, when a fuel gas supply will be required for purge, pilots and ignition for
re-start.
Provide low flow alarms on fuel gas purge points, in line with GP 44-80, 11.5.l.
Confirm that back-up gas from the pipeline can be made available for flare purges/pilots
following site PSD / ESD for start-up, when on-site generated fuel gas will not be available, or,
if not, provide an alternative purge gas, in line with GP 44-80, 11.5.c.4.

9. Other Areas of Concern

9.1 Acoustic Induced Vibration
15
A review of the Acoustic Induced Vibration Assessment Report was undertaken.
The acoustically induced vibration (AIV) screening assessment for the piping systems downstream of
nd
the PSV’s and BDV’s was undertaken using the 2 edition of the Energy Institutes “Guidelines for the
Avoidance of Vibration Induced Fatigue in Process Pipework” and BPs own internal directive
“Assessment of Acoustically Induced Vibration” reference document GN 44-005.
Atkins reviewed the ENPPI document to determine if the scope and findings of the report are in
accordance with industry guidance on the subject of AIV.
Section 3.0 of ENPPI’s document describes the methodology for screening and analysis of AIV. The
assessment is split into two stages; firstly the preliminary AIV assessment which is covered in section
4.0 followed by the detailed assessment in Section 5.0. The AIV assessment is based on BP’s
Assessment of Acoustically Induced Vibration reference document GN 44-005 and Energy Institute
“Guidelines for the Avoidance of Vibration Induced Fatigue in Process Pipework. These documents
are considered industry standard for the assessment of AIV and the screening procedures referenced
within ENPPI’s report.
Section 4.0 of ENPPI’s identifies the lines that are considered to be at risk from AIV; in general these
are lines immediately downstream of PSVs and DBVs where two phase flow could occur. It should
also be noted that the preliminary assessment does not consider the operational hours for each valve
as required by EI guidance.
While cross checking the ENPPI report Appendix A1 with P&IDs it was noted that on sheet 3 of
3 of Appendix A1 SEQ no 67 has the incorrect reference number of 0420-PSV-001B 2020. This
should be as per PI&D which shows valve as 0420-PSV-001B 2026.
Section 5.0 describes the detailed AIV assessment that has been carried out for both cold and wet
flare systems. The assessment has been completed using Section T2.7.3 of the EI guidelines and
BPs own internal directive document GN 44-005.
The calculation of PWL follows BP’s GN 44-005 while the calculation of LOF follow IE’s document.
The preliminary assessment uses 155dB as the limit to determine if any PSVs or BDVs require further
assessment. The detailed assessment utilises Section T2.7.3 from EI documentation and follows the
correct procedures for number of cycles. It should be noted that the majority of sequence numbers
are shown as ‘pass’ although the number of cycles to failure would suggest that a higher LOF than
ENPPI have calculated would be appropriate if the EI assessment methodology is fully followed. The
LOFs calculated by the EI method are likely to result in several areas being highlighted as requiring
modification to mitigate or eliminate AIV.
The recommendations in Section 6.0 are suggested to be applied on a number of lines on the
upstream and downstream of the PSVs and DBVs; 8 on the wet flare system and 1 on the cold flare
system. It is important to consider this during any modification/design work as it is not possible to
determine the proximity of connections on a P+ID. It should also be noted that there may be more
lines that require action as a result of fully completing LOF calculations as described above.
The AIV report should be reviewed in order to meet the requirements of the Energy Institute
and BP’s guidance on AIV assessment. It is specifically recommended that the calculations on
the detailed assessment for the LOF using EI T2.7.3 flowchart including number of cycles are
re-worked.

9.2 Relief and Overpressure System Dossier

Throughout the review, we have found the documentation presented for review to be lacking in
substance and clarity, not commensurate with the status of design and inadequate for defining the
safety critical systems. Whilst GP 44-70 calls for a relief and overpressure system dossier, it does not
mandate a particular format. GP44-70 para 9.4 however does provide a detailed list of what the
dossier should include at Execute. This list is replicated in the table below with the verification team’s
comments as appropriate:
Requirement from GP44-70 9.4 Comment

12
Design philosophy documentation There is a Flare, Blowdown and Vent Philosophy document , a
13
references Flare & Blowdown Basis of Design , an Existing and New
Depressuring Systems Verification Report14, an HP Blowdown
4
Systems Hydraulics Verification Report and an LP Flare and
3
Blowdown Systems Hydraulics Verification Report prepared by
the Project.
It is recommended that effort is spent updating the flare
reports to reflect the final status, supplementing as
necessary to ensure the final deliverable(s) contain
information on the points noted in A2 of GP44-70.
2
List of relieving devices The Existing and New Safety Valves Verification Report
includes a list of relief valves, vents have not been included.
It is recommended that a list of relieving devices in compiled
to include the data required in A3 of GP44-70.
List of removable spools During the course of the review we did not come across any
removable spools.
A list of Removable spools should be included within the
Relief and Overpressure System Dossier if required to limit
relief loads or prevent overpressure scenarios.
Relief loads, calculations, and/or Calculations are presented as an appendix to the Existing and
2
assumptions New Safety Valves Verification Report . The basis for these
calculations is unclear.
All calculated loads should be included within the Relief and
Overpressure System Dossier with key assumptions
included as notes as necessary. Applicable calculation
document numbers should be included for reference. Refer
to GP44-70 A4.
Relief limiting control valves and There is no list that details which control valves, bypass valves
restriction orifices and restriction orifii control the relief load for a particular relief
device.
It is recommended that a list of control valves and ROs be
updated in line with A5 of GP44-70. This should include any
control valve bypasses. This should include assumptions
made in upstream and downstream conditions for relief load
evaluation, and should cross-reference the affected relief
device.
Pumps No data provided

It is recommended that the Relief and Overpressure System
Dossier contain a section on Pumps and Compressors be
compiled in line with A6 of GP44-70.

Compressors See above.

Other equipment data or No data provided.
reference The dossier should contain a section in line with A7 of
GP44-70.
Critical check valves No data provided.
Details of high integrity NRVs should be included within the
Relief and Overpressure System Dossier.
Restricted Cv control valves See above - Relief limiting control valves and restriction orifices
SIS No data provided.
It is recommended that those trips limiting relief load be
incorporated in the Relief and Overpressure System Dossier.
Data recorded should be in line with A8 GP44-70.
Process control loop segregation This does not appear to have been considered when evaluating
relief scenarios.
Fire areas, fire loads, and fire There is some data presented in Existing and New Depressuring
14
resistant insulation (fireproofing) Systems Verification Report .
Details of fire areas, loads etc should be incorporated within
the Relief and Overpressure System Dossier. Data recorded
should be in line with A10 GP44-70.
Flare system details, including These details are included within various documents.
flare header, knockout drum and Flare system details, including flare header, knockout drum
appurtenances, flare stack, flare and appurtenances, flare stack, flare tip, igniter system, etc,
tip, ignitor system, etc should be included within the Relief and Overpressure
System Dossier.
Header pressure profiles These details are included within the HP Blowdown Systems
4
Hydraulics Verification Report and an LP Flare and Blowdown
3
Systems Hydraulics Verification Report .
Maximum tailpipe and header These details are included within the HP Blowdown Systems
4
velocities Hydraulics Verification Report and an LP Flare and Blowdown
3
Systems Hydraulics Verification Report .
LO/LC valve register No data provided.

The Relief and Overpressure System Dossier should include
a list of all locked closed valves which when open would
have a detrimental effect on the relief system; and all locked
open valves which are locked to provide an open path to a
relief route.
HP/LP interface schedule A list of HP/LP interfaces has been included within the Existing
2
and New Safety Valves Verification Report , however this does
not include all pertinent data.
It is recommended that an HP/LP interface schedule be
developed in line with A13 of GP44-70.
Size and type of disposal system Although mentioned in a number of reports it is not clearly stated.
used Relief and Overpressure System Dossier should clearly state
the Size and type of disposal system used.
Relief device inlet/outlet piping The outlet piping hydraulics are included within the HP Blowdown


4
hydraulics Systems Hydraulics Verification Report and an LP Flare and
3
Blowdown Systems Hydraulics Verification Report . Inlet line
sizing calculations are understood to have been carried out.
It is recommended that pertinent data be recorded in the
Relief and Overpressure System Dossier for PSV inlet lines.
Mechanical design basis of It is assumed that these details will be recorded in the piping
process piping and equipment stress analysis report.
It is recommended that a general statement regarding the
mechanical design basis of the flare headers be included
within the Flare Study Report in line with note 19, para 9.4
GP44-70.
Table 9.1 - Summary of Current Flare Documentation against GP44-70

10. References
1
PHPC-WHUPZZ-PM-TOR-001 ToR for the WHX New Flare and Blowdown System – Execute
Stage, Rev C01, October 2012.
2 th
ENP-WHUPZZ-PR-REP-1036 Existing/New Safety Valves Verification Report, Rev G7,12 March
2013.
3
ENP-WHUPZZ-PR-REP-1061 LP Flare and Blowdown System Hydraulics Verification Report, Rev
th
G1, 26 March 2013.
4
ENP-WHUPZZ-PR-REP-1060 HP Blowdown System Hydraulics Report, Rev D3
5
Overpressure Protection Systems, GP 44-70, BP Group Engineering Technical Practices, 24th
February 2010.
6
Line Sizing, Insulation and Heat Tracing Philosophy, ENP-WHUPZZ-PR-PHI-1017 Rev D3, 26th
March 2012.
7
Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries, Part 2 - Installation,
API Recommended Practice 520, 5th Edition, August 2003.
8
Process and Utilities Basis of Design, ENP-WHUPZZ-PR-BOD-1001 Rev G5, 19th September 2012
9
ENPPI Flarenet Model: ENP-WHUPZZ-PR-REP-1060_D2.fnw.
10 th
ENP-WHUPZZ-PI-LST-1086 Line List, Rev F1, 29 July 2012.
11
ENP-WHUPZZ-PR-PHI-1019 West Harbor Expansion Project Emergency Shutdown (ESD)
Philosophy, Rev D2, 12/9/12.
12 th
ENP-WHUPZZ-PR-PHI-1013 Flare, Blowdown and Vent Philosophy, Rev D4, 26 September 2012.
13 th
ENP-WHUPZZ-PR-BOD-1002 Flare and Blowdown Basis of Design, Rev G1, 27 October 2011.
14
ENP-WHUPZZ-PR-REP-1050 Existing and New Depressuring Systems Verification Report, Rev
th
G1, 7 June 2012.
15 th
ENP-WHUPZZ-PI-REP-3028-B1 Acoustic Induced Vibration Assessment Report, Rev B1 7 June
2012.

Appendix A
100% Area Checks
Report No: 5119652/001/PR-REP-001/Rev 0 Page A-1

A.1 Vapour PSV Area Check

ENPPI Atkins ENPPI Atkins
Relieving Rate Adequate
PSV Tag Required Required Orifice Orifice Comments
(kg/h) 2 2 (Y/N)
Area (in ) Area (in ) Designation Designation
0190-PSV-001 1300 0.033 0.033 D D Y
0210-PSV-012A 3288 0.31 0.376 K G N Oversized
0210-PSV-012B 3288 0.31 0.376 K G N Oversized
0210-PSV-021A 1733 0.193 0.161 E E Y
0210-PSV-021B 1733 0.193 0.161 E E Y
0210-PSV-032 1962 0.177 0.181 E E Y
0210-PSV-1004 524 0.03847 0.049 D D Y
0210-PSV-1005 524 0.03847 0.049 D D Y
0210-PSV-1006 1090 0.136 0.136 E E Y
0210-PSV-1007 1090 0.136 0.136 E E Y

0210-PSV-1028A 12453 1.6 1.633 K K Y
0210-PSV-1028B 12453 1.6 1.633 K K Y

0300-PSV-1024A 148146 1.943 1.946 L L Y
0300-PSV-1024B 148146 1.943 1.946 L L Y
0320-PSV-1026 134565 3.323 3.329 M M Y

0320-PSV-1027A 14440 1.948 1.432 L K N Oversized
0320-PSV-1027B 14440 1.948 1.432 L K N Oversized
0320-PSV-1029A 64108 1.45 1.451 K K Y


(kg/h) 2 2 (Y/N)
0320-PSV-1029B 64108 1.45 1.457 K K Y
0320-PSV-1029C 64108 1.45 1.451 K K Y
0320-PSV-1030A 64108 1.45 1.451 K K Y

0320-PSV-1030B 64108 1.45 1.382 K K Y
0320-PSV-1030C 64108 1.45 1.451 K K Y
0320-PSV-1031A 60002 1.35 1.431 K K Y

0320-PSV-1031B 60002 1.35 1.294 K K Y
0320-PSV-1031C 60002 1.35 1.431 K K Y

0320-PSV-1032A 60002 1.35 1.358 K K Y
0320-PSV-1032B 60002 1.35 1.294 K K Y

0320-PSV-1032C 60002 1.35 1.358 K K Y
0320-PSV-109A 3624 0.073 0.073 G D N

0320-PSV-109B 3624 0.073 0.073 G D N
0320-PSV-209A 3624 0.073 0.073 G D N

0320-PSV-209B 3624 0.073 0.073 G D N Valves are oversized. Could
lead to chattering and valve
0320-PSV-309-1A 4254 0.086 0.086 G D N failure.
0320-PSV-309-1B 4254 0.086 0.086 G D N
0320-PSV-309-2A 4254 0.086 0.086 G D N
0320-PSV-309-2B 4254 0.086 0.086 G D N
0360-PSV-1000A 9367 0.192 0.178 F E N Oversized


(kg/h) 2 2 (Y/N)
0360-PSV-1000B 9367 0.192 0.178 F E N Oversized
0360-PSV-1002A 11616 0.237 0.237 F F Y
0360-PSV-1002B 11616 0.237 0.237 F F Y

0360-PSV-801A 13515 0.275 0.276 F F Y
0360-PSV-801AC 9437 0.192 0.179 F E N Oversized
0360-PSV-801AD 9437 0.192 0.179 F E N Oversized

0360-PSV-801B 13515 0.275 0.276 F F Y
0360-PSV-801BC 9437 0.192 0.179 F E N Oversized

0360-PSV-801BD 9437 0.192 0.179 F E N Oversized
0360-PSV-811A 258283 5.674 5.682 P P Y

0360-PSV-811B 258283 5.674 5.682 P P Y
0360-PSV-812 17403 1.948 1.842 L L Y

0360-PSV-812A 17403 1.948 1.948 L L Y
0360-PSV-821A 13515 0.275 0.276 F F Y

0360-PSV-821B 13515 0.275 0.276 F F Y
0360-PSV-831A 258283 5.674 5.682 P P Y
0360-PSV-831AC 185672 4.35 4.348 P P Y

0360-PSV-831AD 185672 4.35 4.348 P P Y
0360-PSV-831B 258283 5.674 5.682 P P Y
0360-PSV-831BC 185672 4.35 4.143 P N N Oversized


(kg/h) 2 2 (Y/N)
0360-PSV-831BD 185672 4.35 4.143 P N N Oversized
0360-PSV-831CC 185672 4.35 4.348 P P Y
0360-PSV-831CD 185672 4.35 4.348 P P Y

0390-PSV-1040 203 0.056 0.056 D D Y
0420-PSV-001A 4050 0.11 0.109 D D Y
0420-PSV-001B 4050 0.11 0.109 D D Y

0420-PSV-1007 527 0.015 0.015 D D Y
0420-PSV-1008A 8118 2.852 2.854 L M N Valves are undersized, however

it is marginal and hence L orifice
0420-PSV-1008B 8118 2.852 2.854 L M N is acceptable.
0420-PSV-801A 30000 1.529 1.531 K K Y

0420-PSV-801B 30000 1.529 1.531 K K Y
0600-PSV-1001A 1420 0.287 0.286 F F Y

0600-PSV-1001B 1420 0.287 0.286 F F Y

0600-PSV-1006A 2000 0.27 0.272 F F Y
0600-PSV-1006B 2000 0.27 0.272 F F Y
0850-PSV-002A 20596 1.229 1.229 J J Y


(kg/h) 2 2 (Y/N)
0850-PSV-002B 20596 1.229 1.229 J J Y
0850-PSV-1005A 2615 0.314 0.31 G G Y
0850-PSV-1005B 2615 0.314 0.31 G G Y

0850-PSV-1023A 258283.3 5.065 4.78 P P Y
0850-PSV-1023B 258283.3 5.065 4.78 P P Y
0850-PSV-1025 2010 0.784 0.78 H H Y
0420-PSV-1033A 840 0.503 0.35 G G Y
0420-PSV-1033B 840 0.503 0.35 G G Y

Table A.1 – Check on Area and Selected Orifice for Relief Devices in Vapour Service

A.2 Liquid PSV Area Check

PSV Tag Relieving Rate ENPPI Atkins ENPPI Atkins Adequate Comments
(kg/h) Required Required Orifice Orifice (Y/N)
2 2
0390-PSV-1003 2787.8 0.048 0.046 D D Y
0210-PSV-041 24128 0.471 0.471 G G ? Valves see 2 phase flow and

0210-PSV-051 24128 0.471 0.471 G G ? should be sized accordingly.
Table A.2 – Check on Area and Selected Orifice for Relief Devices in Liquid Service

A.3 Blowdown Orifice Area Check

FO Tag BDV Tag Flow (kg/h) ENPPI Size (mm) Size Atkins (mm) Discrepancy %
0360-FO-1000 0360-BDV-1002 12160 13.95 16.83 21

0360-FO-1001
0360-BDV-1003 10210 13.33 16.80 26
0360-FO-111C 0360-BDV-912C 32590 24.74 30.22 22
0300-FO-1004 0300-BDV-1001 304100 8X20.99 133.73 24
0850-FO-1000 0850-BDV-1001 103600 8X10.82 38.76 27
0850-FO-1005 0300-BDV-014 4033 8.03 9.69 21
0320-FO-101 0320-BDV-101 4521 8x2.96 9.72 16
0320-FO-102 0320-BDV-102 5243 4x4.96 11.85 -9
0320-FO-201 0320-BDV-201 4521 8x2.96 9.72 16
0320-FO-202 0320-BDV-202 5243 4x4.96 11.84 -9
0320-FO-301A 0320-BDV-202 4521 8x2.96 9.72 16
0320-FO-302A 0320-BDV-202 5243 4x4.96 11.85 -9
0320-FO-301B 0320-BDV-202 4521 8x2.96 9.72 16
0320-FO-302B 0320-BDV-202 5243 4x4.96 11.84 -9
0320-FO-1001 0320-BDV-202 2883 7.5 9.29 24

FO Tag BDV Tag Flow (kg/h) ENPPI Size (mm) Size Atkins (mm) Discrepancy %
0190-FO-1004 0190-BDV-006 672.8 3.62 4.48 24
0190-FO-1005 0190-BDV-303 1578 5.92 7.05 19
0190-FO-1006
0190-BDV-304 986.2 4.61 5.57 21
0850-FO-1006 0850-BDV-009 500 4.47 5.44 22
0850-FO-1024 0210-BDV-021 350.6 5.73 6.88 20
0230-FO-101 0230-BDV-902 167.2 2.63 2.76 5
Table A.3 – Check on Blowdown Orifice Area

Appendix B
Critical Relief Device Evaluation
Report No: 5119652/001/PR-REP-001/Rev 0 Page B-1

B.1 Critical Relief Device Summary

Relief Valve System ENPPI Sizing Required Selected Atkins Sizing Relief load Selected Comments
2 2
Case Relief load Orifice (in ) Case (kg/h) Orifice (in )
(kg/h)
0210-PSV- Glycol / HC The PSV is
021A/B Separator (0210- External Fire 4,127 undersized
VA-001) based on both
the fire and
reverse flow
Fire 1,733 E J case - due to a
larger latent heat
Reverse Flow 8,009 and smaller area
used within
ENPPI
calculations.
0210-PSV- Condensate Fire 524 External Fire 830 The PSV is
1005 Preheater Tube Abnormal undersized
Side (0210-HA- 1,157 based on
Heat
002A) abnormal heat
Liquid D E case – lower
Thermal 1,093 wetted area and
Expansion Thermal Relief N/A latent heat used
in ENPPI
calculations
0210-PSV- Condensate External Fire 6,457 The PSV is
1006 Preheater Shell undersized
Side (0210-HA- based on the fire
002A) case – minimum
Fire 1,090 E G
Tube rupture 11,937 latent heat from
API used in
Atkins
calculations
0210-PSV- Condensate External Fire 5,817 PSV is
1028A/B Stabiliser 0210- Control Valve undersized for
Fire 12,453 K T
VE-001 Failure of 85.65 gas blowby
0210-FV-022 (accelerated

2 2
(kg/h)
Control Valve liquid and
Failure of 3,538 abnormal heat
0210-FV-035 input.
Blocked
53.5
vapour outlet
Blocked liquid
4,278
Outlet
Gas Blowby 3,315 Gas Blowby
4,025
(vapour)
Gas Blowby
(accelerated 275,229
liquid)
Liquid Overfill 19,452
Abnormal
193,196
heat input
300-PSV- Ha’py Slugcatcher External Fire – The PSV is
1024A/B 300-VQ-001 Liquid 29,346 undersized
(water+HC) based on the fire
External Fire case, where
Fire 148,146 L 183,989 M
– Liquid (HC) condensate only
External Fire – has been
12,695 considered.
Vapour
3
Blocked Outlet 0.01 m /h
0320-PSV- Hanover LT External Fire - The PSV is
707
1026 Separator (0320 Liquid adequately
VA 401) External Fire - sized.
Blocked 3355
134,565 M Vapour M
Outlet
Control Valve
128,599
Failure
Blocked Outlet 122,332
0320-PSV Gas/Gas External Fire - The PSV is
1029-A/B/C Exchanger Shell Blocked undersized for
128,215 K Vapour 34,424
Side (0320 HA Outlet full open bypass
Expansion

2 2
(kg/h)
001A/B) External Fire - around 0320-
Liquid 7,320 FCV-103
Vaporisation
Control Valve
Failure (0320-
802,304
Fire 29,366 J FCV-103 8”
bypass valve)
0360-PSV-801 Onshore Gas Fire – vapour PSV is
949
AC/BC Compressor HP expansion oversized.
Suction Drum C Fire – liquid
Fire 13,515 F 697 D
(0360 VA 001C) case (H2O)
Fire – liquid
903
case (Glycol)
0360-PSV- Onshore Gas Blocked PSV adequately
Block 371,344 499,300
831- Compressor Discharge sized but ENPPI
AC/BC/CC Discharge C (0360 flowrate based
VA 001C) 2P 2P on normal flow
Fire 3,237 Fire 222,741 through
compressor plus
10%.
0360-PSV- Onshore Gas External Fire - PSV is
1000A/B Compressor HP Vapour 7808 oversized.
Discharge Drum C Expansion
(0360 VA 002C) External Fire -
Liquid
697
Fire 9367 F Vaporisation E
(H2O)
External Fire -
Liquid
903
Vaporisation
(Diesel)

2 2
(kg/h)
0390-PSV- Exhaust Glycol The PSV is
3 3
1003 Pump Blocked outlet 2.6 m /h D Blocked outlet 2 m /h D adequately
0390-PD-002D sized.
0390-PSV- Exhaust Glycol The PSV is
External Fire -
1040 Filter Fire 203 D 281 D adequately
Liquid
0390-CL-003D sized.
0390-PSV-605 Exhaust Glycol Unknown – no
External Fire -
Filter N/A N/A N/A 193 D data on existing
Liquid
0390-CL-601A valve available.
0420-PSV- HP Fuel Gas KO Fire (Vapour The PSV is
1,025
801A/B Drum Control valve filled vessel) undersized
30,000
420-VA-002 failure Control valve based on the
36,622
failure PV201 control valve
K Control valve L (PV201) failure
failure 33,897 case.
Fire 625 PCV202
Blocked
10,437
outlets
0420-PSV- Fuel Gas Start-up External Fire - The PSV is
179
1007 Heater vapour adequately
Fire 527 D D
420-HM-002 Abnormal Heat sized.
132
Input
0420-PSV- LP Fuel Gas KO External fire The PSV is
1008A/B Drum (vapour filled 277 undersized for
420-VA-001 Control Valve vessel) failure of
Failure (0420- 7,450 Control valve PV007A/B plus
PV-007) failure PV- bypass.
1,227
L 1004 plus FO- Q
1001
Control valve
Control Valve
failure
Failure (0420- 31,852 19,448
PV007A/B
PV-1004)
plus bypass

2 2
(kg/h)
Control valve
failure PV-
3,921
023A plus
bypass
Control valve
failure PV-
2,303
035B plus
Fire 1,574
bypass
Blocked
1,410
outlets
0600-PSV- Nitrogen Control valve The PSV is
2,310
1006 Distribution Header failure undersized
Control Valve Blocked based on the
2,000 F 188 G
Failure outlets control valve
Abnormal heat failure case.
HOLD
input
0850-PSV- Water / HC External pool The PSV is
1,286
002A/B Separator fire (max HC) undersized
0850-VA-001 Gas blowby External pool based on the
(0850-FCV- fire (max 1,881 gas blowby
20,596
001) Taurt water) case.
Slugcatcher CV failure
(0850-FCV- 193,800
001)
CV failure
J 14,241 Q
(0300-FV-001)
Gas blowby
(0850-FCV- 1,328,433
External pool
001) Taurt (liquid)
fire (max 504
Slugcatcher
water)
Gas blowby
(0850-FCV- 50,502
001) Taurt (vapour)
Slugcatcher

2 2
(kg/h)
Gas blowby
External pool (0300-FV-001)
2,531 116,047
fire (max HC) Ha’py
Slugcatcher
Total blocked
Gas blowby 10,249
outlets
(0300-FV-001)
13,568 Blocked
Ha’py
outlets 40
Slugcatcher
(vapour)
0850-PSV- Condensate Outlet Control Valve The PSV is
1005 of 0850FCV002 undersized
Water/Hydrocarbon 7,567 based on the
Fails Open:
Separator (0850 Liquid Flow Accelerated
VA 001) Control Valve Liquid Flow
0850FCV002 case.
Control Valve Fails Open: 135,941
4,190 G Accelerated P
Failure
Liquid Flow
Control Valve
0850FCV002
2,818
Fails Open:
Gas Blowby
Blocked Outlet 3486
850-PSV- Taurt Slugcatcher The PSV is
External Fire 11,315
1023A/B 850-VQ-001 undersized
External Fire – based on the
Blocked vapour 1443 inadvertent valve
258,283 P expansion 6T+Q
Discharge opening case.
Inadvertent
9,200,054
valve opening
0850-PSV- Methanol Storage External Fire 2,016 The PSV is
1025 Tank, 0850-TC- Fire 2,010 H Control valve R undersized for all
3,345
003 failure cases with the

2 2
(kg/h)
Reverse Flow exception of
from Methanol reverse flow
6776
Injection - (methanol).
methanol
Reverse Flow
from
Methanol
312,807
Injection –
displaced
liquid
Reverse Flow
from Methanol
1709
Injection -
vapour
Table B.1 – Comparison of Critical Devices

Appendix C
Relief Device Selection
Report No: 5119652/001/PR-REP-001/Rev 0 Page C-1

C.1 Relief Device Selection

PSV Tag Type Phase Device Device Design Upstream Conditions SUIMP Built- Total % Back Adequate
Set Conditions Back up Back pres pres (Y/N)
Pres Pres Back
(barg) Pres
Pres T(°C)
barg T(°C) barg bar barg
(barg) min/max
0190-PSV-001 Conventional V 110.0 N/A N/A 133.1 272 6.82 3.3 10.12 3.0% Y
0210-PSV-012A Balance Bellows V 15.0 N/A N/A 18.15 218 7.16 2.38 9.54 64% N
0210-PSV-012B Balance Bellows V 15.0 N/A N/A 18.15 218 7.16 2.38 9.54 64% N
0210-PSV-021A Balance Bellows V 18.4 N/A N/A 22.264 216 7.33 0.3 7.63 41% Y
0210-PSV-021B Balance Bellows V 18.4 N/A N/A 22.264 216 7.33 0.3 7.63 41% Y
0210-PSV-032 Balance Bellows V 9.2 N/A N/A 11.132 140 7.16 1 8.16 89% N
0210-PSV-1004 Balance Bellows V 17.5 18.4 N/A 21.175 229 7.16 0.13 7.29 42% Y
0210-PSV-1005 Balance Bellows V 17.5 18.4 N/A 21.175 229 7.16 0.13 7.29 42% Y
0210-PSV-1006 Balance Bellows V 14.5 15.0 N/A 17.5329 218 7.16 0.85 8.01 55% N
0210-PSV-1007 Balance Bellows V 14.5 15.0 N/A 17.5329 218 7.16 0.87 8.03 55% N
0210-PSV-1028A Pilot V 9.2 9.2 N/A 11.132 298 7.33 0.56 7.89 86% Y
0210-PSV-1028B Pilot V 9.2 9.2 N/A 11.132 298 7.33 0.56 7.89 86% Y
0300-PSV-1024A Pilot V 110.0 110.0 N/A 133.1 286 6.33 9.2 15.53 14% Y
0300-PSV-1024B Pilot V 110.0 110.0 N/A 133.1 286 6.33 9.2 15.53 14% Y
Pilot Operated
V 100.0 N/A 93.5 12.15 14% Y
0320-PSV-1026 Modulating 85.0 55 7.9 4.25
0320-PSV-1027A Balance Bellows V 17.5 18.4 N/A 19.25 -65 7.4 2 9.4 54% N
0320-PSV-1027B Balance Bellows V 17.5 18.4 N/A 19.25 -65 7.4 2 9.4 54% N
0320-PSV-1029A Balance Bellows V 85.0 85.0 N/A 98.6 47 7.8 5.94 13.74 16% Y
0320-PSV-1029B Balance Bellows V 89.3 85.0 N/A 98.175 47 7.8 5.94 13.74 15% Y

Pres Pres Back
(barg) Pres
Pres T(°C)
(barg) min/max
0320-PSV-1029C Balance Bellows V 85.0 85.0 N/A 98.6 47 7.8 5.94 13.74 16% Y
0320-PSV-109A Conventional V 110.0 N/A N/A 133.1 276 7.68 9.4 17.08 8.5% Y
0320-PSV-109B Conventional V 110.0 N/A N/A 133.1 276 7.68 9.4 17.08 8.5% Y
0320-PSV-309-1A Conventional V 110.0 N/A N/A 133.1 276 7.33 7.5 14.83 6.8% Y
0320-PSV-309-1B Conventional V 110.0 N/A N/A 133.1 276 7.4 7.37 14.77 6.7% Y
0320-PSV-309-2A Conventional V 110.0 N/A N/A 133.1 276 7.33 7.5 14.83 6.8% Y
0320-PSV-309-2B Conventional V 110.0 N/A N/A 133.1 276 7.4 7.5 14.9 6.8% Y
0360-PSV-1000A Conventional V 110.0 110 N/A 133.1 332 6.37 1.75 8.12 1.6% Y
0360-PSV-1000B Conventional V 110.0 110 N/A 133.1 332 6.37 1.75 8.12 1.6% Y

Pres Pres Back
(barg) Pres
Pres T(°C)
(barg) min/max
0360-PSV-801AC Conventional V 110.0 110 N/A 133.1 332 6.37 1.6 7.97 1.5% Y
0360-PSV-801AD Conventional V 110.0 N/A N/A 133.1 332 6.37 1.6 7.97 1.5% Y
0360-PSV-801BC Conventional V 110.0 110 N/A 133.1 332 6.37 1.6 7.97 1.5% Y
0360-PSV-801BD Conventional V 110.0 N/A N/A 133.1 332 6.37 1.6 7.97 1.5% Y
0360-PSV-811A Pilot V 110.0 N/A N/A 121 104 6.85 6.37 13.22 12% Y
0360-PSV-811B Pilot V 110.0 N/A N/A 121 104 6.85 6.37 13.22 12% Y
Pilot Operated
V N/A N/A 20.24 10.7 58% Y
0360-PSV-812 Modulating 18.4 15 6.8 3.9
Pilot Operated
V 18.4 N/A 20.24 10.7 58% Y
0360-PSV-812A Modulating 18.4 15 6.8 3.9
0360-PSV-831A Pilot V 110.0 N/A N/A 121 104 6.85 5.7 12.55 11% Y
Pilot Operated
V 110.0 N/A 121 13.34 12% Y
0360-PSV-831AC Modulating 110.0 106 6.37 6.97
Pilot Operated
V N/A N/A 121 13.34 12% Y
0360-PSV-831AD Modulating 110.0 106 6.37 6.97
0360-PSV-831B Pilot V 110.0 N/A N/A 121 104 6.85 5.7 12.55 11% Y
Pilot Operated
V 110.0 N/A 127.05 13.34 12% Y
0360-PSV-831BC Modulating 115.5 106 6.37 6.97
Pilot Operated
V N/A N/A 127.05 13.34 12% Y
0360-PSV-831BD Modulating 115.5 106 6.37 6.97

Pres Pres Back
(barg) Pres
Pres T(°C)
(barg) min/max
Pilot Operated
V 110.0 N/A 121 13.34 12% Y
0360-PSV-831CC Modulating 110.0 106 6.37 6.97
Pilot Operated
V N/A N/A 121 13.34 12% Y
0360-PSV-831CD Modulating 110.0 106 6.37 6.97
0390-PSV-1040 Conventional V 8 8.0 N/A 9.68 191 0.8 0.8 10.0% Y
0420-PSV-1007 Conventional V 85.0 85.0 N/A 102.85 130 6.42 1.8 8.22 2.1% Y
0420-PSV-1008A Pilot V 5.0 5.0 N/A 5.5 21 1.64 0.44 2.08 42% Y
0420-PSV-1008B Pilot V 5.0 5.0 N/A 5.5 21 1.64 0.44 2.08 42% Y
0420-PSV-801A Conventional V 40.0 N/A N/A 44 39 1.64 2 3.64 5.0% Y
0420-PSV-801B Conventional V 40.0 N/A N/A 44 39 1.64 2 3.64 5.0% Y
0460-PSV-1022A Conventional V 10.6 10.6 N/A 12.826 215 0 1 1 9.4% Y
0460-PSV-1022B Conventional V 10.6 10.6 N/A 12.826 215 0 1 1 9.4% Y
0600-PSV-1006A Conventional V 10.6 10.6 N/A 11.66 -19 0 1 1 9.4% Y
0600-PSV-1006B Conventional V 10.6 10.6 N/A 11.66 -19 0 1 1 9.4% Y
0850-PSV-002A Conventional V 40.0 N/A N/A 44 49 6.4 3.2 9.6 8.0% N
0850-PSV-002B Conventional V 40.0 N/A N/A 44 49 6.4 3.2 9.6 8.0% N

Pres Pres Back
(barg) Pres
Pres T(°C)
(barg) min/max
Pilot Operated
V 110.0 N/A 121 15.45 14% Y
0850-PSV-1023A Modulating 110.0 40 6.4 9.05
Pilot Operated
V 110.0 N/A 121 15.45 14% Y
0850-PSV-1023B Modulating 110.0 40 6.4 9.05
0850-PSV-1025 Conventional V 3.5 3.5 N/A 4.235 115 0.21 0.35 0.56 10.0% Y
0420-PSV-1033A Conventional V 5 N/A N/A 6.05 134 0.16 0.2 0.36 4.0% Y
0420-PSV-1033B Conventional V 5 N/A N/A 6.05 134 0.16 0.2 0.36 7% Y

L/ 2-
0210-PSV-041 Balance Bellows 15
N/A N/A 16.5 1.5 1.5 3 20% Y
phase
L/ 2-
0210-PSV-051 Balance Bellows 15
N/A N/A 16.5 1.5 1.5 3 20% Y
phase
0390-PSV-1003 Conventional L 8 N/A N/A 8.8 1.5 0.8 2.3 10.0% Y
Table C.1 – Relief Device Selection

Appendix D
Inlet Line Verification
Report No: 5119652/001/PR-REP-001/Rev 0 Page D-1

D.1 Inlet piping drainage, isolation and winterisation

PSV Inlet Inlet Drain
Block Valve Slopes (from Winterisation
PSV Tag Equipment Flange Line Valve Adequate
(inches) isometric) (Y/N)
(inches) (inches) (Y/N)
Onshore Gas Compressor HP 3’’ Interlocked Horizontal

0360-PSV-801AC 1 1/2 3 Y N N
Suction Drum (0360-VA-001C) Open section(s)
Onshore Gas Compressor HP 3’’ Interlocked Horizontal

0360-PSV-801BC 1 1/2 3 Y N N
Suction Drum (0360-VA-001C) Closed section(s)
Onshore Gas HP discharge 8’’ Interlocked Horizontal

0360-PSV-831AC 4 8 Y N N
Coolers (0360-HC-001C) Open section(s)
Onshore Gas HP discharge 8’’ Interlocked Horizontal

0360-PSV-831BC 4 5 Y N N
Coolers (0360-HC-001C) Open section(s)
0360-PSV- Onshore Gas HP discharge 8’’ Interlocked Horizontal

4 5 Y N N
831CC Coolers (0360-HC-001C) Closed section(s)
Onshore Gas Compressor HP
3’’ Interlocked Horizontal
0360-PSV-1000A Discharge Drum (0360-VA- 1 1/2 3 Y N N
Open section(s)
002C)

0360-PSV-1000B Discharge Drum (0360-VA- 1 1/2 3 Y N N
Closed section(s)
002C)
Onshore Gas Compressor HP 3’’ Interlocked Isometrics not

0360-PSV-801AD 1 1/2 3 Y N N
Suction Drum (0360-VA-001D) Open available
Onshore Gas Compressor HP 3’’ Interlocked Isometrics not Isometrics not

0360-PSV-801BD 1 1/2 3 Y N
Suction Drum (0360-VA-001D) Closed available available


Onshore Gas HP discharge 8’’ Interlocked Isometrics not Isometrics not

0360-PSV-831AD 4 8 Y N
Coolers (0360-HC-001D) Open available available
Onshore Gas HP discharge 8’’ Interlocked Isometrics not Isometrics not

0360-PSV-831BD 4 8 Y N
Coolers (0360-HC-001D) Open available available
0360-PSV- Onshore Gas HP discharge 8’’ Interlocked Isometrics not Isometrics not
4 8 Y N
831CD Coolers (0360-HC-001D) Closed available available
1 1/2 3’’ Interlocked Isometrics not Isometrics not
0360-PSV-1002A Discharge Drum (0360-VA- 3 Y N
Open available available
002D)

1 1/2 3’’ Interlocked Isometrics not Isometrics not
0360-PSV-1002B Discharge Drum (0360-VA- 3 Y N
Closed available available
002D)
Fuel Gas Startup Heater (0420- 2’’ Locked Horizontal

0420-PSV-1007 1 2 Y N N
HM-002) Open section(s)

0460-PSV-1022A Wet Air Receiver (0460-VA-004) 1 1/2 2 Y N N
Closed section(s)

0460-PSV-1022B Wet Air Receiver (0460-VA-004) 1 1/2 2 Y N N
Open section(s)
Nitrogen Receiver (0600-VA- 3’’ Interlocked Horizontal
0600-PSV-1001A 1 1/2 3 Y N N
004) Open section(s)
Nitrogen Receiver (0600-VA- 3’’ Interlocked Horizontal

0600-PSV-1001B 1 1/2 3 Y N N
004) Closed section(s)


Nitrogen Backup Storage Bullet 3’’ Interlocked Horizontal

0600-PSV-1003A 1 1/2 3 Y N N
(0600-VA-001) Open section(s)
Nitrogen Backup Storage Bullet 3’’ Interlocked Horizontal

0600-PSV-1003B 1 1/2 3 Y N N
(0600-VA-001) Closed section(s)
Nitrogen Backup Heater (0600- 2’’ Interlocked Horizontal

0600-PSV-1006A 1 1/2 2 Y Y N
HM-001) Open section(s)
Nitrogen Backup Heater (0600- 2’’ Interlocked Horizontal

0600-PSV-1006B 1 1/2 2 Y Y N
HM-001) Closed section(s)
1 1/2’’
Pig Receiving Trap (0190-VR- Interlocked Isometrics not Isometrics not
0190-PSV-001 1 1/2 1 1/2 N N
001) Open available available
Ha'py Slug Catcher (0300-VQ- 6’’ Interlocked Horizontal

0300-PSV-1024A 4 6 Y N N
Ha'py Slug Catcher (0300-VQ- 6’’ Interlocked Horizontal

0300-PSV-1024B 4 6 Y N N
10’’
Tuart Slug Catcher (0850-VQ- Horizontal
0850-PSV-1023A 4 10 Interlocked Y N N
001) section(s)
Open
10’’
Tuart Slug Catcher (0850-VQ- Horizontal
0850-PSV-1023B 4 10 Interlocked Y N N
001) section(s)
Closed
Onshore Gas Compressor HP 3’’ Locked Isometrics not Isometrics not

0360-PSV-801A 1 1/2 3 Y N
Suction Drum (0360-VA-001A) Open available available


Onshore Gas Compressor HP 3’’ Interlocked Isometrics not Isometrics not

0360-PSV-801B 1 1/2 3 Y N
Suction Drum (0360-VA-001A) Closed available available
Onshore Gas Compresssor HP 3’’ Interlocked Isometrics not Isometrics not

0360-PSV-821A 1 1/2 3 Y N
Suction Drum (0360-VA-001B) Open available available
Onshore Gas Compresssor HP 3’’ Interlocked Isometrics not Isometrics not

0360-PSV-821B 1 1/2 3 Y N
Suction Drum (0360-VA-001B) Closed available available

6’’ Locked Horizontal
0360-PSV-811A Discharge Cooler (0360-HC- 4 6 Y N N
Open section(s)
001A)

0360-PSV-811B Discharge Cooler (0360-HC- 4 6 Y N N
Closed section(s)
001A)

6’’ Locked Isometrics not Isometrics not
0360-PSV-831A Discharge Cooler (0360-HC- 4 6 Y N
Open available available
001B)

4 6’’ Locked Isometrics not Isometrics not
0360-PSV-831B Discharge Cooler (0360-HC- 8 Y N
Closed available available
001B)
6” Locked Horizontal
0360-PSV-812 Unit 0360 (to 0210-HA-001A) 3 6 N N N
Open section(s)
0360-PSV-812A Unit 0360 (to 0210-HA-001A) 3 6 N N N
Closed section(s)


Tube side of Gas/Gas 2’’ Locked Isometrics not Isometrics not

0320-PSV-109A 2 3 Y N
Exchanger (0320-HA-001A/B) Closed available available
Tube side of Gas/Gas 2’’ Locked Isometrics not Isometrics not

0320-PSV-109B 2 3 Y N
Exchanger (0320-HA-001A/B) Open available available
Shell side of Gas/Gas 4’’ Locked Horizontal

0320-PSV-1029A 3 4 Y N N
Exchanger (0320-HA-001A/B) Open section(s)
0320-PSV-1029B 3 4 Y N N
Exchanger (0320-HA-001A/B) Open section(s)

0320-PSV-1029C 3 4 Y N N
Exchanger (0320-HA-001A/B) Closed section(s)
Tube side of Gas/Gas 2” Interlocked Isometrics not Isometrics not

0320-PSV-209A 2 3 Y N
Tube side of Gas/Gas 2” Locked Isometrics not Isometrics not
0320-PSV-209B 2 3 Y N
Shell side of Gas/Gas 4’’ Locked Horizontal Horizontal

0320-PSV-1030A 3 4 Y N
Exchanger (0320-HA-002A/B) Open section(s) section(s)

0320-PSV-1030B 3 4 Y N
Exchanger (0320-HA-002A/B) Open section(s) section(s)

0320-PSV-1030C 3 4 Y N
Exchanger (0320-HA-002A/B) Closed section(s) section(s)
Tube Side Condensate 6’’ Interlocked Horizontal

0320-PSV-1027A 3 6 Y Y N
Preheater (0320-HA-002A/B) Open section(s)


Tube Side Condensate 6’’ Interlocked Horizontal

0320-PSV-1027B 3 6 Y Y N
Preheater (0320-HA-002A/B) Closed section(s)
Slopes directly
before PSV are
greater than
0320-PSV-309- Tube side of Gas/Gas 3’’ Interlocked Isometrics not
2 3 1:200, however Y N
1A Exchanger (0320-HA-003A/B) Closed available
isometrics for
upstream lines
missing
Slopes directly
before PSV are
greater than
2A Exchanger (0320-HA-003A/B) Open available
isometrics for
upstream lines
missing
Shell Side of Gas/Gas 4’’ Locked Isometrics not Isometrics not
0320-PSV-1031A 3 4 Y N

0320-PSV-1031B 3 4 Y N
0320-PSV-1031C 3 4 Y N
Slopes directly
before PSV are
greater than
1B Exchanger (0320-HA-003C/D) Open available
isometrics for
upstream lines
missing


0320-PSV-309- Tube side of Gas/Gas 3’’ Interlocked Horizontal

2 3 Y N N
2B Exchanger (0320-HA-003C/D) Closed section(s)
Slopes directly
before PSV are
greater than
Shell Side of Gas/Gas 4’’ Locked Isometrics not
0320-PSV-1032A 3 4 1:200, however Y N
Exchanger (0320-HA-003C/D) Open available
isometrics for
upstream lines
missing
Slopes directly
before PSV are
greater than
0320-PSV-1032B 3 4 1:200, however Y N
Exchanger (0320-HA-003C/D) Open available
isometrics for
upstream lines
missing
Slopes directly
before PSV are
greater than
0320-PSV-1032C 3 4 1:200, however Y N
Exchanger (0320-HA-003C/D) Closed available
isometrics for
upstream lines
missing

0320-PSV-1026 Hanover LTS (0320-VA-401) 4 6 Y N N
Open section(s)
Water/Hydrocarbon Separator 3’’ Locked Isometrics not Isometrics not
0850-PSV-002A 3 4 Y N
(0850-VA-001) Open available available
Water/Hydrocarbon Separator 3’’ Locked Isometrics not Isometrics not

0850-PSV-002B 3 4 Y N
(0850-VA-001) Closed available available


Water/Hydrocarbon Separator 3” Interlocked Horizontal

0850-PSV-1005A 1 1/2 3 Y N N
Liq Oulet (0850-VA-001) Open section(s)
Water/Hydrocarbon Separator 3” Interlocked Horizontal

0850-PSV-1005B 1 1/2 3 Y N N
Liq Oulet (0850-VA-001) Closed section(s)
Tube Side Condensate 2’’ Locked Horizontal

0210-PSV-1004 1 2 Y N N
Preheater (0210-HA-002B) Open section(s)
Tube Side Condensate 2’’ Locked Horizontal

0210-PSV-1005 1 2 Y N N
Preheater (0210-HA-002A) Open section(s)
Shell Side Condensate 2’’ Locked Horizontal

0210-PSV-1006 1 2 Y N N
Preheater (0210-HA-002A) Open section(s)
Shell Side Condensate 2’’ Locked Horizontal
0210-PSV-1007 1 2 Y N N
Preheater (0210-HA-002B) Open section(s)
Stabilizer Column (0210-VE- 4” Interlocked Horizontal
0210-PSV-1028A 3 4 Y N N
Stabilizer Column (0210-VE- 4” Interlocked Horizontal
0210-PSV-1028B 3 4 Y N N
Water Decant Drum (0210-VA- Isometrics not Isometrics not
0210-PSV-032 1 2 N/A N N
002) available available
Stabilizer Reboiler (0210-FA- Isometrics not Isometrics not
0210-PSV-041 1 1/2 1 1/2 N/A N N
001A) available available
Stabilizer Reboiler (0210-FA- Isometrics not Isometrics not

0210-PSV-051 1 1/2 1 1/2 N/A N N
001B) available available
Condensate Cooler (0210-HC- 6” Interlocked Horizontal
0210-PSV-012A 3 6 Y N N


Condensate Cooler (0210-HC-
0210-PSV-012B 6” Interlocked Horizontal
001) 3 6 N N N
Closed section(s)
Slopes ok (but
Isometrics not
Glycol/HC Separator (0210-VA- 1” Locked Isometrics not
0210-PSV-021A 1 2 available between N N
001) Open available
TP-575/576 &
Vessel)
Slopes ok (but
Isometrics not
Glycol/HC Separator (0210-VA- 1” Locked Isometrics not
0210-PSV-021B 1 2 available between N N
001) Closed available
TP-575/576 &
Vessel)
Exhaust Glycol Pump D (0390- 2” Locked Slope towards
0390-PSV-1003 1 2 Y N N
PD-002D) Open PSV
Exhaust Glycol Filter D (0390- 1 2 2” Locked Horizontal

0390-PSV-1040 Y N N
CL-003D) Open section(s)
Methanol Storage Tank (0850- Horizontal

0850-PSV-1025 1 1/2 4 N/A N N N
TC-003) section(s)
Slopes directly
before PSV are
greater than
1” Locked Isometrics not
0420-PSV-001A Fuel Gas Heater (0420-HM-001) 1 1 1/2 1:200, however Y N
Open available
isometrics for
upstream lines
missing


Slopes directly
before PSV are
greater than
1” Locked Isometrics not
0420-PSV-001B Fuel Gas Heater (0420-HM-001) 1 1 1/2 1:200, however Y N
Open available
isometrics for
upstream lines
missing
Fuel Gas Knock Out Drum
0420-PSV-1008A (0420-VA-001) 3 6 Y N N
Open section(s)
Fuel Gas Knock Out Drum
0420-PSV-1008B (0420-VA-001) 3 6 Y N N
Open section(s)
6” Locked
HP Fuel Gas Knock Out Drum Open Horizontal
0420-PSV-801A 3 6 Y N N
(0420-VA-002) Interlocked section(s)
Open
6” Locked
HP Fuel Gas Knock Out Drum Closed Horizontal
0420-PSV-801B 3 6 Y N N
(0420-VA-002) Interlocked section(s)
Closed

BDV Inlet Inlet Drain

BDV Tag Equipment Flange Line Valve Adequate
0360 Future onshore Horizontal

0360-BDV-1002 6 6 6” Locked Open Horizontal section(s) Y N
gas comp HP Discharge section(s)
0360 Compressor
0360-BDV-1003 6 6 6” Locked Open Horizontal section(s) Y N N
Suction Header
0360-BDV-912C 0360-VA-002C Train C 8 8 8” Locked Open Horizontal section(s) N N N
Ha’py Slug Catcher 12” Locked

0300-BDV-1001 12 12 Horizontal section(s) Y N N
(0300-VQ-001) Open
Tuart Slug Catcher Horizontal

0850-BDV-1001 4 4 4” Locked Open Horizontal section(s) Y N
(0850-VQ-001) section(s)
Tuart Slug Catcher

0300-BDV-014 2 2 2” Locked Open Missing isometrics Y N Missing isometrics
(0850-VQ-001)
Gas Exchanger (0320-
HA-001B)

HA-001B)

HA-002B)

HA-002B)
Unit 0320 Gas
0320-BDV-301A 2 3 2” Locked Open Missing isometrics Y N Missing isometrics
Exchanger C/D

0320-BDV-302A 3 6 3” Locked Open Missing isometrics Y N Missing isometrics
HA-003A/B)

BDV Inlet Inlet Drain

BDV Tag Equipment Flange Line Valve Adequate
Unit 0300 Gas

0320-BDV-301B 2 3 2” Locked Open Missing isometrics Y N Missing isometrics
Interpiping Skid

0320-BDV-302B 3 6 3” Locked Open Missing isometrics Y N Missing isometrics
HA-003C/D)
Low temperature
0320-BDV-1001 Separator (0320-VA- 4 4 4” Locked Open Horizontal section(s) Y N N
401)
Unit 0320 (LTS-2) Gas

Exchangers & Separator
Unit 0320 (LTS-2) Gas

Exchangers & Separator
Unit 0320 (LTS-2) Gas 1 1/2” Locked
0190-BDV-304 11/2 11/2 Missing isometrics Y N Missing isometrics
Exchangers & Separator Open
Water/ HC Separator
(0850-VA-001)
Glycol/HC Separator
(0210-VA-001)
HP Fuel KO Drum
0230-BDV-902 3 3 / Horizontal section(s) N N N
(0420-VA-002)

D.2 Inlet Line Losses Calculations

Set Rated
Existing/ Atkins Atkins Adequate
PSV Tag Type Equipment Pressure Phase Flow Comments
New ΔP (bar) % (Yes/No)
(barg) (kg/h)
Isometrics missing
0210 PSV 021A/B Existing B/B 0210-HA-VA-001 18.4 V 1756 0.186 1.0% Y between TP-575/TP-576
and 0210-VA-001
Fire Case. Thermal
expansion case 0.80 bar
0210 PSV 1005 New B/B 0210-HA-002A 17.5 V 1498 0.52 3.0% N
pressure drop, 4.6% of
set pressure
0210 PSV 1006 New B/B 0210-HA-002A 14.5 V 1572 0.354 2.4% Y
0210 PSV 1028A/B New Pilot 0210-VE-001 9.2 V 14306 0.94 10.2% N Rated flow
0210 PSV 1028A/B New Pilot 0210-VE-001 9.2 V 12453 0.71 7.7% N Required flow
0300 PSV 1024A/B New Pilot 0300-VQ-001 110 V 217420 0.749 0.7% Y Rated flow
0320 PSV 1026 Existing Pilot 0320-VA-401 85 V 145756 3.04 3.6% N Rated flow
0320 PSV 1029A/C Existing Conv. 0320-HA-001A/B 85 V 81097 1.421 1.7% Y
0320 PSV 1029B Existing Conv. 0320-HA-001A/B 89 V 81550 1.552 1.7% Y
0360 PSV 801AC/BC New Conv. 0360-VA-001C 110 V 15076 0.22 0.2% Y
0360 PSV 831AC/CC New Pilot 0360-HC-001C 110 V 272360 1.73 1.6% Y Rated flow
0360 PSV 831BC New Pilot 0360-HC-001C 115 V 272360 1.71 1.5% Y Rated flow
0360 PSV 1000A/B New Conv. 0360-VA-001C 110 V 15076 2.045 1.9% Y
0390 PSV 515 Unable to assess - Isometric between vessel and TP-319 missing
0390 PSV 1003 New Conv. 0390-PD-002D 8 L 7567 0.092 1.2% Y
0390 PSV 1040 New Conv. 0390-CL-003D 8 V 397 0.065 0.8% Y
0390 PSV ? Unable to assess as Isometric not available
0420 PSV 801A/B Existing Conv. 0420-VA-002 40 V 36071 1.371 3.4% N
0420 PSV 1007 New Conv. 0420-HM-002 85 V 3865 0.855 1.0% Y

Set Rated
Existing/ Atkins Atkins Adequate
PSV Tag Type Equipment Pressure Phase Flow Comments
New ΔP (bar) % (Yes/No)
(barg) (kg/h)
Missing isometric for line
0420-410-FG-4"-1A3
0420 PSV 1008A/B Existing Pilot 0420-VA-001 5 V 8119 0.42 8.4% N
Tp346 to 0420-VA-001.
Rated Flow
Missing isometric for line
0420-410-FG-4"-1A3
0420 PSV 1008A/B Existing Pilot 0420-VA-001 5 V 8118 0.42 8.4% N
Tp346 to 0420-VA-001.
Required flow.
Only A valve done as B
0600 PSV 1006A/B New Conv. 0600HM001 10.6 V 2259 0.84 7.9% N
valve Isometric missing
0850 PSV 002A/B Existing Conv. 0850-VQ-001 Unable to assess as Isometric not available
Only A valve done as B
0850 PSV 1005A/B New B/B 0850-HA-002A 17.5 V 4190 0.415 2.4% Y valve. Isometric missing
for TP-591 to FCV-002
Isometric only up to TP-
0850 PSV 1023 Existing Conv. 0850-VQ-001 110 V 325302 3.97 3.6% N
060.
0850 PSV 1025 Existing Conv. 0850-TC-003 3.5 V 2013 0.276 7.9% N

Appendix E
Tail Pipe and Flare Header Summary
Report No: 5119652/001/PR-REP-001/Rev 0 Page E-1

E.1 Tail Pipe Summary
Block Valve Port Size
Isometric Length (m)

Outlet Valve Locked
Flarenet Length (m)

Outlet Block Valve
Relief Valve Outlet
Angle of Entry to
Flange (in)
Insulation
Pockets
Size (in)
Material
Header
Note 1
Phase
Open
Line No. Description Slope Comments
Horizontal section Horizontal section and section

0210-257-BD- 0210-PSV-021A Tail and section sloping towards PSV outlet.
None 2 2 HOLD Yes CS None LV 45 4.2 2.506
3"-1A3-V pipe sloping towards Reused valve - non listed
PSV outlet symbol
Horizontal section and section
sloping towards PSV outlet. PSV
Horizontal section outlet block valve (on
0210-258-BD- 0210-PSV-021B Tail and section Glycol/HC Separator standby
None 2 2 HOLD No CS None LV 45 1.9 2.514
3"-1A3-V pipe sloping towards PSV) should be LO as per
PSV outlet Flare, Relief and Vent
Philosophy. Reused valve -
non listed symbol
Not Sufficient -
0210-401-BD- sections with Not Sufficient - sections with
PSV-1005 tail pipe None 3 2 FB Yes CS None LV 45 13.8 1.905
3"-1A3-V slope less than slope less than 1:400.
1:400
0210-402-BD- 0210-PSV-1006 Tail Not Sufficient - Horizontal
Horizontal section None 4 2 FB Yes CS None LV 45 13.8 1.93
4"-1A3-V pipe section.
0210-247-BD- 0210-PSV-1028B Not Sufficient - Horizontal
Horizontal section None 6 4 FB Yes CS Yes LV HOLD 3.4 HOLD
6"-1A3-P Tail pipe section. Isometric not available
0210-248-BD- 0210-PSV-1028A
HOLD HOLD HOLD HOLD HOLD HOLD HOLD HOLD LV HOLD HOLD HOLD HOLD. Isometric not available
6"-1A3-P Tail pipe
0300-413-BD- 0300-PSV-1024A/B Not Sufficient - Horizontal
10"-1A3-V Tail pipe section.
0300-413-BD- 0300-PSV-1024A/B Not Sufficient - Horizontal
10"-1A3-V Tail pipe section.
Not Sufficient - Horizontal
Different section. P&ID and flarenet
0320-253-BD- P0320-PSV-1026
Horizontal section None 12 6 FB Yes CS None LV 45 destination 9.353 shows BD-253 tying into BD-409
12"-1A3-V Tail pipe
in flarenet where Isometrics show tie into
BD-819 (TIP 125)


Outlet Valve Locked
Flarenet Length (m)

Outlet Block Valve
Relief Valve Outlet
Angle of Entry to
Flange (in)
Insulation
Pockets
Size (in)
Material
Header
Note 1
Phase
Open

0320-301-BD- 0320-PSV-1029A section. Isometric missing for
Horizontal Section None 10 4 FB Yes CS None LV HOLD 2.9 3.665
10"-1A3-V Tail pipe BD213 drawing ENP-WHUPZZ-
PI-Isometric-9432

0320-301-BD- 0320-PSV-1029B section. Isometric missing for
Horizontal Section None 10 4 FB Yes CS None LV HOLD 2.9 3.665
10"-1A3-V Tail pipe BD213 drawing ENP-WHUPZZ-
PI-Isometric-9433
Not Sufficient -
0360-302-BD- 0360-PSV-801AC sections with Not Sufficient - sections with
None 6 3 FB Yes LTCS None LV 45 5.5 4.355
6"-1B3-V Tail pipe slope less than slope less than 1:400.
1:400
Not Sufficient -
0360-303-BD- 0360-PSV-801BC sections with Not Sufficient - sections with
6"-1B3-V Tail pipe slope less than slope less than 1:400.
1:400
0360-305-BD- 0360-PSV-831AC Not Sufficient - Horizontal
Horizontal Section None 12 6 FB Yes LTCS None LV 45 4 4.352
12"-1B3-V Tail Pipe section.
0360-306-BD- 0360-PSV-831BC Not Sufficient - Horizontal
Horizontal Section None 12 6 FB Yes LTCS None LV 45 4 4.358
12"-1B3 Tail Pipe section.
0360-217-BD- 0360-PSV-831CC Section sloping Section sloping back towards
None 12 6 FB Yes LTCS None LV 45 5 4.361
12"-1B3 Tail Pipe back towards PSV PSV.
0360-309-BD- 0360-PSV-1000A Not Sufficient - Horizontal
Horizontal Section None 6 3 FB Yes LTCS None LV 45 5.5 4.363
6"-1B3-V Tail Pipe section.
Not Sufficient -
0360-310-BD- 0360-PSV-1000B sections with Not Sufficient - sections with
6"-1B3-V Tail Pipe slope less than slope less than 1:400.
1:400
LP model
Horizontal Section None 4 2 FB Yes CS None LV 45 not 2.951
4"-1A3-V Pipe section.
available


Outlet Valve Locked
Flarenet Length (m)

Outlet Block Valve
Relief Valve Outlet
Angle of Entry to
Flange (in)
Insulation
Pockets
Size (in)
Material
Header
Note 1
Phase
Open
Sloping back
0390-614-GY- 0390-PSV-1003 Tail
towards PSV None 2 2 FB Yes CS None L Relieves back into process
2"-1A3-V pipe
outlet
0390-627-GY- 0390-PSV-1040 Tail

Horizontal Section None 2 2 FB Yes CS None L Relieves back into process
2"-1A3-V pipe
Cold Flare
0230-430-BD- 0420-PSV-801A Tail Not Sufficient - Horizontal
Horizontal Section None 8 4 FB Yes LTCS None LV 45 model not 2.821
8"-1B3-V Pipe section.
available
Cold Flare
0230-443-BD- 0420-PSV-801B Tail Not Sufficient - Horizontal
Horizontal Section None 8 4 FB Yes LTCS None LV 45 model not 3.005
8"-1B3-V Pipe section.
available
Not Sufficient - Not Sufficient - sections with
Cold Flare
0420-400-BD- 0420-PSV-1007 Tail sections with slope less than 1:400. Isometric
None 4 2 FB Yes LTCS None LV HOLD model not 12.879
4"-1B3-V pipe slope less than missing for 6"-FH-0012-01CS-
available
1:400 2PW
Cold Flare
Horizontal Section None 6 4 FB Yes SS None LV 45 model not 3.301
1C1-V Tail pipe section.
available
Cold Flare
Horizontal Section None 6 4 FB Yes SS None LV 45 model not 2.974
1C1-V Tail pipe section.
available
0600-203-UN- 0600-PSV-1006B
Atmospheric Vent
2"-1B3-F Tail Pipe
0600-204-UN- 0600-PSV-1006A
Atmospheric Vent
2"-1B3-F Tail Pipe
0850-005-BD- 0850-PSV-002A/B Cannot evaluate. Isometric not

HOLD HOLD 4 4 FB Yes LTCS None LV 0
6"-1B-V Tail pipe available


Outlet Valve Locked
Flarenet Length (m)

Outlet Block Valve
Relief Valve Outlet
Angle of Entry to
Flange (in)
Insulation
Pockets
Size (in)
Material
Header
Note 1
Phase
Open

Horizontal Section None 6 3 FB Yes LTCS None LV 3 2.969
6"-1B3-V Tail pipe section.

Horizontal Section None 6 3 FB Yes LTCS None LV 45 5.5 4.333
6"-1B3-V Tail pipe section.

0850-400-BD- 0850-PSV-1023A
Horizontal Section None 12 6 FB Yes SS None LV 45 18 16.689 section. Isometric not available
12"-1C1-V Tail pipe
for 0850-012-BD-12"-1C-N
Horizontal Section None 12 6 FB Yes SS None LV 45 5.8 5.993
12"-1C1-V Tail pipe section.
LP model
Horizontal Section None 4 3 FB Yes CS None LV 45 not 0.899
available
LP model
Horizontal Section None N/A N/A N/A N/A CS None LV 45 not 48.592
available

E.2 Sub-header Summary
Isometric Length
Angle of Entry to
Flarenet Length
(m) Note 1
Insulation
Pockets
Material
Header
Phase
(m)
LP model
Isometric not available for 0230-003-BD-8"-
0230-407-BD-8"-1A3-V LP Sub Header Sufficient None CS None LV 45 not 138.773
A02-V
available
LP model Sections where slope is <1:400 despite

Sections where slope is <1:400
0390-266-BD-6"-1A3-V LP Sub Header None CS None LV 45 not 3.144 being labelled as 1:400. Isometric only
despite being labelled as 1:400.
available available up to TP-322A
Not Sufficient - sections with Not Sufficient - sections with slope less than
0210-404-BD-4"-1A3-V Wet Flare Sub header None CS None LV 45 3.2 9.118
slope less than 1:400 1:400.
Not Sufficient - sections with slope less than
Not Sufficient - sections with
1:400 and horizontal section. Isometric
0210-408-BD-6"-1A3-V Wet Flare Sub header slope less than 1:400 and None CS None LV 90 5.2 1.976
shows BD-408 tying into BD-267 but P&ID
horizontal section
shows tie into BD-409
0210-409-BD-24"-1B3-
Wet Flare Sub header HOLD None LTCS None HOLD HOLD 33.6 HOLD HOLD. Not on Isometric register
V
0230-267-BD-36"-1A3- Not Sufficient - sections with Not Sufficient - sections with slope less than
Wet Flare Sub header None CS None LV HOLD 12.3 1.356
V slope less than 1:400 1:400. Isometric only available to TP-122B
TP-122A
0230-267-BD-36"-1A3- Not Sufficient - sections with not Not Sufficient - sections with slope less than
Wet Flare Sub header None CS None LV HOLD 6.796
V slope less than 1:400 shown 1:400. Isometric only available to TP-122A
on model
0230-400-BD-20"-1B3- Sections where slope is <1:400 Sections where slope is <1:400 despite
Wet Flare Sub header None LTCS None LV 45 39.5 13.595
V despite being labelled as 1:400. being labelled as 1:400.
Sections where slope is <1:400
Sections where slope is <1:400 despite
0230-408-BD-24"-1B3- despite being labelled as 1:400.
Wet Flare Sub header None LTCS None LV 45 28 159.826 being labelled as 1:400. End section of the
V End section of the header slopes
header slopes wrong way..
wrong way.
0230-819-BD-15"-1B3- Not in Horizontal Section. Isometric not available
Wet Flare Sub header Horizontal Section None LTCS None LV HOLD 2.873
V model for 0230-004-BD-16"-A36-V
TP-261A
0300-007-BD-10"-A06- Horizontal section. Isometric only available
Wet Flare Sub header Horizontal section None CS None N/A HOLD not in 0.723
V up to TP-261A
flarenet

Isometric Length
Angle of Entry to
Flarenet Length
(m) Note 1
Insulation
Pockets
Material
Header
Phase
(m)
TP-260 Sections where slope is <1:400 despite

0850-273-BD-20"-1C1- Sections where slope is <1:400
Wet Flare Sub header None SS None LV HOLD not in 5.183 being labelled as 1:400.. Isometric not
V despite being labelled as 1:400.
model available for 0850-019-BD-20"-1C-N
0230-275-BD-20"-1B3- Not Sufficient - slope less than

Wet Flare Sub header None LTCS None LV 90 69.8 75.88 Not Sufficient - slope less than 1:400.
V 1:400
0230-411-BD-20"-1C1- Not Sufficient - slope less than Not in Not Sufficient - slope less than 1:400.
Wet Flare Sub header None SS None LV 2.579
V 1:400 model Isometric only available to TP-045
Section near TP-046 slope is
Section near TP-046 slope is 1:1500. Other
1:1500. Other sections where
0230-437-BD-18”-1A3- sections where slope is <1:400 despite
Wet Flare Sub header slope is <1:400 despite being None CS/LTCS None LV 90 211.8 223.117
V being labelled as 1:400. Section with 1:625.
labelled as 1:400. Section with
. Isometric only available to TP-046
1:625.

E.3 Header Summary
Isometric Length
Flarenet Length
(m) Note 1
Insulation
Pockets
Material
(m)
Isometric only available to TP-044.

Part of the line labelled as 0230-
Not Sufficient - sections with slope
0230-413-BD-36"-1B3-V Wet Flare header None LTCS No 138.4 146.038 416-BD-1B3-V in flarenet. Not
less than 1:400
Sufficient - sections with slope less
than 1:400
Cold
Flare
Sections where slope is <1:400 Sections where slope is <1:400
0230-425-BD-20"-1B3-V Cold Flare Header Yes LTCS No model 554.988
despite being labelled as 1:400. despite being labelled as 1:400.
not
available
LP model
0230-003-BD-8"-A02 LP Flare Header Horizontal Section None CS No not 0.321 Horizontal Section
available

Appendix F
HP Wet Flare model Review
Report No: 5119652/001/PR-REP-001/Rev 0 Page F-1

F.1 Review of HP Wet Flare Model
The model of the HP Wet Flare Header for the WHX Project does not reflect information from PSV sizing calculations or isometrics. The relief loads for all
new and existing PSVs were checked against calculation data (listed in Table 1 of Verification Report ENP-WHUPZZ-PR-REP-1036 Rev G6) and there were
many inconsistencies in relation to rated and required relief flowrates, set pressures and accumulation. However, no PSVs have been run in any of the flare
scenarios. There are also discrepancies between the isometrics (see Proforma 6.0) and P&IDs in terms of pipework routing, lengths and location of tie in
points.
It should be noted that the flarenet model is Rev D2, and the HP Blowdown System Hydraulic Verification Report of the same document number is Rev D3,
which could be the reason the data does not match. The flare model should be updated to provide an accurate model of the network in order to size headers
and sub headers correctly and evaluate the back pressures within the system.
HP Model (file name ENP-WHUPZZ-PR- Adequate

Check REP-1060) (Yes/No) Impact
CALCULATION METHODS
VLE method Peng Robinson Yes
Enthalpy method Peng Robinson Yes
Heat transfer enabled Yes Yes
Kinetic energy included Yes Yes
Pressure Drop Method Beggs and Brill (Homog.) Yes
All Design Warnings selected except for Ice
Warnings Formation. Yes
CONSTRAINTS
Mach No 0.8 (tailpipes and headers) Yes Consistent with Philosophy
Noise 155 (tailpipes and headers) Yes Consistent with Philosophy
2
Rho V2 Not used No Should be incorporated using ρv < 200 000
Violations 193 violations No Temperature and MABP only. Should be resolved.


SCENARIO DEVELOPMENT
As can be seen in App A of the HP Blowdown Verification
The HP Blowdown Verification Report (ENP- Report the scenarios included in the model represent the
WHUPZZ-PR-REP-1060 Rev D3) lists 12 worst cases.
possible blowdown scenarios (1A, 1B, 1C, No loads present in 1C, 3A, 4A or 8 which are not
2A/B, 3A,3B, 4A, 4B, 6, 7 and 8). The cases modelled in the other scenarios.
included in the flarenet model are Case 1A, None of these scenarios take into account PSVs
Scenarios 1B, 2A, 2B, 3B, 4B, 6 & 7). Yes activating
Liquid rated flows
independently calculated?
(Version 2006.5 only) N/A N/A N/A
All existing and new PSVs have been

included with the exception of 0420-PSV-
1007 from fuel gas system and 0360-PSV-
1002A/B, 0360-PSV-801AD/BD and 0360-
PSV-831AD/BD/CD from future compressor Connections for valves for compressor train D, although
train D. to be installed in the future, should be considered in the
All sources included All BDVs have been included. Yes current model to ensure it can be easily updated.
Set pressures correct Set Pressures entered are correct Yes
Relief valve size correct All sizes are correct. Yes
22 of the PSVs included in the model (not
including duty standbys) have had either the
required or rated capacity entered The model requires the correct flowrates to size pipework
Gov relief load entered incorrectly. No accurately. No PSVs were included in the scenarios.
PIPEWORK
Nominal size correct, fittings and lengths The lengths and fittings used in the model seem to be
used in the model do not match those used preliminary estimates and do not correlate to the
Main header check in isometrics. Yes isometrics.
The lengths and fittings used in the model seem to be
Fittings and lengths used in the model do preliminary estimates and do not correlate to the
Isometrics used not match those used in isometrics. No isometrics.


Pipe Material Specification (ENP-WHUPZZ-PI-SPE-3000
Rev D6) note 6 on all CS and SS pipework that maximum
temperature limit is 150⁰C due to ball valve seat material.
LTCS has min temperature of -46⁰C, normal CS is -29⁰C
Design temperatures -46/400 CS and -69/500 SS No and SS is -98⁰C.
Piping schedules used are not consistent Internal diameter can have a significant effect on pressure
Schedule with the pipe material specification No drop calculations.
0.46 mm would be more conservative for a flare header
0.15mm for Carbon Steel and 0.046mm for system (CS), as per GP44-80, particularly as much of it
Roughness Stainless Steel Yes has been in use for sometime.
Tailpipes identified Yes Yes
Fittings have been entered but do not match
Pipework isometrics No Model should be updated to reflect isometrics
Fittings Loss - Miller with Miller Chart
Tees extrapolation - Gardel Yes
FLARE TIPS
Two pressure entries. Tip vendor data to be added when
Flare tip curves used Yes Yes available.
Flare tip pressure correction Yes Yes

Appendix G
Calculations
Report No: 5119652/001/PR-REP-001/Rev 0 Page G-1

G.1 Calculations
The following calculations are included.
Calculation Number Description
5119652-PR-CA-001 Glycol/HC Separator 0210 VA 001
5119652-PR-CA-002 Condensate Preheater TS 0210 HA 002A
5119652-PR-CA-003 Condensate Preheater SS 0210 HA 002A

5119652-PR-CA-004 Stabiliser Column 0210 VE 001
5119652-PR-CA-005 H’apy Slugcatcher 0300 VQ 001
5119652-PR-CA-006 Hanover LT Separator 0320 VA 401

5119652-PR-CA-007 Gas/Gas Exchangers 0320 HA 001A/B
5119652-PR-CA-008 Gas Compressor Suction Drum 0360 VA 001C
5119652-PR-CA-009 Gas Compressor Discharge 0360 K 001C
5119652-PR-CA-010 Gas Compressor Discharge Drum 0360 VA 002C
5119652-PR-CA-012 Glycol Pump Discharge 0390 PD 002D
5119652-PR-CA-013 Cartridge Filter 0390 CL 003D
5119652-PR-CA-014 Glycol Regen Package 0390 XY 007
5119652-PR-CA-015 HP Fuel Gas Drum 0420 VA 002
5119652-PR-CA-016 Fuel Gas Start-up Heater 0420 HM 002
5119652-PR-CA-017 LP Fuel Gas Drum 0420 VA 001
5119652-PR-CA-018 Nitrogen Distribution Header
5119652-PR-CA-019 Water/HC Separator 0850 VA 001
5119652-PR-CA-020 Condensate outlet 0850 VA 001
5119652-PR-CA-021 Taurt Slugcatcher 0850 VQ 001
5119652-PR-CA-022 Methanol Tank 0850 TC 003
5119652-001-CA-100 Vapour PSV Area Check
5119652-001-CA-101 Liquid PSV Area Check

5119652-001-CA-104 Blowdown Area Verification
5119652-001-CA-201 Inlet Line Check of 0210-PSV-021A/B
5119652-PR-CAL-202 Inlet Line Pressure Drop Check 0210-PSV-1005 - Liquid

Expansion
5119652-PR-CAL-203 Inlet Line Pressure Drop Check 0210-PSV-1005 -Fire Case
5119652-PR-CAL-204 Inlet line check 0210-PSV-1006
5119652-PR-CAL-205 Inlet Line Pressure Drop Check 0210-PSV-1028A/B
5119652-PR-CAL-206 Inlet Line Pressure Drop Check 0210-PSV-1028A/B -

Required Flow

5119652-PR-CAL-208 Inlet Line Pressure Drop Check 0320-PSV-1026

5119652-PR-CAL-210 0360-PSV-801-AC/BC Inlet Line Check
5119652-PR-CAL-211 Inlet line Check 0360-PSV-831AC

5119652-PR-CAL-212 Inlet line Check 0360-PSV-831BC
5119652-PR-CAL-213 Inlet line Check 0360-PSV-831CC

5119652-PR-CAL-216 Inlet Line Check 0390-PSV-1040
5119652-PR-CAL-217 Inlet line Size check 0420-PSV-801A/B

5119652-PR-CAL-219 Inlet Line Check 0420-PSV-1008A/B
5119652-PR-CAL-220 Inlet Line Check 0420-PSV-1008A/B - Required flow
5119652-PR-CAL-221 Inlet Line Pressure Drop Check 0600-PSV-1006A
5119652-PR-CAL-223 Line Sizing Check 0850-PSV-1023A/B

200 Broomielaw
Glasgow
G1 4RU
Telephone: 0141 220 2000

Fax: 0141 220 2001
email: info@atkinsglobal.com
www.atkinsglobal.com
© Atkins Ltd except where stated otherwise

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and the strapline 'Plan Design Enable' are trademarks
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Independent Verification of WHX

New Flare and Blowdown System

Independent Verification of WHX New Flare and Blowdown System

Atkins Pharaonic Petroleum Company

Tel: 0141 220 2000 Tel: 00 202 27725900

Report No: 5119652/001/PR-REP-001/Rev 0 Page 2

DOCUMENT ISSUE CONTROL SHEET

Pharaonic Petroleum Company

Independent Verification of WHX New Flare and Blowdown System

Issue Date Purpose Rev Prepared Checked Approved

1 June 2013 Draft for Client Comment 0 GRD/AJR AJR/GRD GRD

Report No: 5119652/001/PR-REP-001/Rev 0 Page 3

Report No: 5119652/001/PR-REP-001/Rev 0 Page 4

7.1 Emergency Shutdown ................................................................................................................ 6

Report No: 5119652/001/PR-REP-001/Rev 0 Page 5

Report No: 5119652/001/PR-REP-001/Rev 0 Page 6

Report No: 5119652/001/PR-REP-001/Rev 0 Page 7

Report No: 5119652/001/PR-REP-001/Rev 0 Page 8

AIV Acoustically Induced Vibration

ASME American Society of Mechanical Engineers

BOD Basis of Design

BUBP Built-up Back Pressure

CFD Computational Fluid Dynamics

ESD Emergency Shutdown

FEED Front End Engineering Design

HAZOP Hazard and Operability Study

IPS Instrumented Protection System

LOF Likelihood of Failure

LOPA Layer of Protection Analysis

LTCS Low Temperature Carbon Steel

PAHH Pressure Alarm High High

PSD Process Shutdown

PSHH Pressure Switch High High

PSV Pressure Safety Valve

PWL Sound Power Level

SIL Safety Integrity Level

SIS Safety Instrumented System

USD Unit Shutdown

Report No: 5119652/001/PR-REP-001/Rev 0 Page 9

Report No: 5119652/001/PR-REP-001/Rev 0 Page 10

Recommendation 13 – Section 5.2.2.10

Report No: 5119652/001/PR-REP-001/Rev 0 Page 11

Recommendation 25 – Section 6.2.1.2

Report No: 5119652/001/PR-REP-001/Rev 0 Page 12

Recommendation 38 – Section 6.4.1

Report No: 5119652/001/PR-REP-001/Rev 0 Page 13

Report No: 5119652/001/PR-REP-001/Rev 0 Page 14

Recommendation 60 – Section 7.3.3

Report No: 5119652/001/PR-REP-001/Rev 0 Page 15

Recommendation 73 – Section 8.3

Report No: 5119652/001/PR-REP-001/Rev 0 Page 16

Recommendation 85 – Section 9.2

Report No: 5119652/001/PR-REP-001/Rev 0 Page 17

4. Compliance with ETPs and International

4.2 Areas of Non-Conformance

Ref Standard Paragraph Deviation Impact

1 GP 44-70 6.2a Causes of overpressure are Whilst it is realised that many of

GP 44-70 7.3 The potential to overfill the Relief device potentially

Report No: 5119652/001/PR-REP-001/Rev 0 Page 18

Ref Standard Paragraph Deviation Impact

GP 44-70 10.2.3h Backpressure exceeds 50% Relief device potentially

GP 44-80 7.5b Radiation levels at the site Exposure of the public to

GP 44-80 8.3.b. There is no evidence of an Potential for unmitigated